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 allowed admission of additional documentary evidence concerning intra-group services and interest on outstanding receivables, finding the materials go to the root of the controversy and require examination by the AO. The Tribunal declined to remit the matter to the DRP, holding the DRP functus officio after issuing directions under s.144C(5) and not a proper appellate forum for remand. The Tribunal set aside the final assessment and restored the matter to the AO for fresh adjudication of the transfer pricing adjustment and interest, directing the AO to verify the newly admitted evidence, afford the assessee opportunity of hearing, and pass a fresh order in accordance with law. Appeal allowed for statistical purposes.
The ITAT allowed admission of additional documentary evidence concerning intra-group services and interest on outstanding receivables, finding the materials go to the root of the controversy and require examination by the AO. The Tribunal declined to remit the matter to the DRP, holding the DRP functus officio after issuing directions under s.144C(5) and not a proper appellate forum for remand. The Tribunal set aside the final assessment and restored the matter to the AO for fresh adjudication of the transfer pricing adjustment and interest, directing the AO to verify the newly admitted evidence, afford the assessee opportunity of hearing, and pass a fresh order in accordance with law. Appeal allowed for statistical purposes.
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TaxTMI 
TaxTMI 
of 4918 
