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 set aside the dismissal of the appeal by the CIT(A)/NFAC for non-compliance with section 249(4) regarding deposit of demand before filing the appeal. The appellant contended that a return of income was filed and the entire tax liability was satisfied through TDS. The tribunal found that the CIT(A)/NFAC failed to consider the appellant's submission that the return was filed under a PAN allotted in the status of a firm, despite the appellant being a company, and did not provide an opportunity to explain this. Consequently, the matter was remitted to the CIT(A)/NFAC for de novo adjudication with directions to verify the appellant's claims and admit the appeal if the conditions under section 249(4) are met.
The ITAT set aside the dismissal of the appeal by the CIT(A)/NFAC for non-compliance with section 249(4) regarding deposit of demand before filing the appeal. The appellant contended that a return of income was filed and the entire tax liability was satisfied through TDS. The tribunal found that the CIT(A)/NFAC failed to consider the appellant's submission that the return was filed under a PAN allotted in the status of a firm, despite the appellant being a company, and did not provide an opportunity to explain this. Consequently, the matter was remitted to the CIT(A)/NFAC for de novo adjudication with directions to verify the appellant's claims and admit the appeal if the conditions under section 249(4) are met.
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