Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
The ITAT allowed the appellant's appeal concerning the disallowance of sums claimed under an MOU with another entity, rejecting the revenue's contention that the arrangement was a tax evasion device. The Tribunal found no cogent material supporting the addition and upheld the appellant's claim based on the available evidence. However, the appeal against additions under section 40(a)(ii) relating to income tax paid and deferred tax liability was dismissed as infructuous, since the appellant had already adjusted these amounts in the return, and the Assessing Officer was directed to correct the computation accordingly. Consequently, the addition based on the MOU was deleted, while the tax computation was maintained consistent with the appellant's filings.
The ITAT allowed the appellant's appeal concerning the disallowance of sums claimed under an MOU with another entity, rejecting the revenue's contention that the arrangement was a tax evasion device. The Tribunal found no cogent material supporting the addition and upheld the appellant's claim based on the available evidence. However, the appeal against additions under section 40(a)(ii) relating to income tax paid and deferred tax liability was dismissed as infructuous, since the appellant had already adjusted these amounts in the return, and the Assessing Officer was directed to correct the computation accordingly. Consequently, the addition based on the MOU was deleted, while the tax computation was maintained consistent with the appellant's filings.
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TaxTMI 
TaxTMI 
of 4918 
