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 the first ground in favor of the revenue pursuant to the assessee's concession and the revenue's non-objection, resulting in the appellate tribunal upholding the TP adjustment for notional interest on outstanding receivables from an associated enterprise without adjudicating the substantive merits. Conversely, the ITAT set aside the disallowance under section 14A read with Rule 8D, restoring the Commissioner (Appeals) order in favour of the assessee on the basis that no exempt income was earned and therefore no s.14A disallowance was warranted, following precedential treatment of the assessee's earlier assessment year.
The ITAT allowed the first ground in favor of the revenue pursuant to the assessee's concession and the revenue's non-objection, resulting in the appellate tribunal upholding the TP adjustment for notional interest on outstanding receivables from an associated enterprise without adjudicating the substantive merits. Conversely, the ITAT set aside the disallowance under section 14A read with Rule 8D, restoring the Commissioner (Appeals) order in favour of the assessee on the basis that no exempt income was earned and therefore no s.14A disallowance was warranted, following precedential treatment of the assessee's earlier assessment year.
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TaxTMI 
TaxTMI 
of 4918 
