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...
ITAT restored multiple grounds to the file of the AO and CIT(A). Ground No.2 (tree-cut compensation) was remitted to the AO for verification of genuineness and for the assessee to produce detailed payments and court orders to substantiate capital expenditure. Ground No.3 (provision for obsolescence/MAT add-back) was remitted for the AO to determine whether the sum is a provision within Explanation 1(i) to s.115JB or an actual write-off; if an actual write-off, it need not be added back. The appeal against taxability of compensation under the RFCTLARR Act was restored to the file of the CIT(A) for fresh adjudication on the claim of exemption.
ITAT restored multiple grounds to the file of the AO and CIT(A). Ground No.2 (tree-cut compensation) was remitted to the AO for verification of genuineness and for the assessee to produce detailed payments and court orders to substantiate capital expenditure. Ground No.3 (provision for obsolescence/MAT add-back) was remitted for the AO to determine whether the sum is a provision within Explanation 1(i) to s.115JB or an actual write-off; if an actual write-off, it need not be added back. The appeal against taxability of compensation under the RFCTLARR Act was restored to the file of the CIT(A) for fresh adjudication on the claim of exemption.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
