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...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
The ITAT upheld the CIT(A)'s decision disallowing the AO's addition of interest expenses, holding that since the assessee had commenced business operations, the interest expenditure qualifies as allowable revenue expenditure for the impugned year. Additions related to credit card payments and depreciation/amortization were deleted, as the expenses were duly accounted for by the subsidiary and appropriately adjusted in income computation. The Tribunal affirmed the CIT(A)'s jurisdiction to entertain the claim for deduction of premium on Non-Convertible Debentures raised for the first time on appeal, ruling such premium, being in the nature of interest, is an allowable revenue deduction. Regarding carry forward of losses, the AO was directed to reconsider the assessee's submissions, with no impact on tax liability. Grounds of appeal challenging these findings were dismissed accordingly.
The ITAT upheld the CIT(A)'s decision disallowing the AO's addition of interest expenses, holding that since the assessee had commenced business operations, the interest expenditure qualifies as allowable revenue expenditure for the impugned year. Additions related to credit card payments and depreciation/amortization were deleted, as the expenses were duly accounted for by the subsidiary and appropriately adjusted in income computation. The Tribunal affirmed the CIT(A)'s jurisdiction to entertain the claim for deduction of premium on Non-Convertible Debentures raised for the first time on appeal, ruling such premium, being in the nature of interest, is an allowable revenue deduction. Regarding carry forward of losses, the AO was directed to reconsider the assessee's submissions, with no impact on tax liability. Grounds of appeal challenging these findings were dismissed accordingly.
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TaxTMI 
TaxTMI 
of 4918 
