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...
ITAT held that the penalty under s.270A(2) for underreporting was unsustainable and directed its deletion where the assessee, during scrutiny for AY 2020-21, surrendered an incorrect deduction for education cess in light of the retrospective amendment to s.40(a)(ii) effected by Finance Act 2022. The Tribunal found the assessee complied with the proviso to s.155(18) by honestly surrendering the claim and paying tax within the statutory window (to 31-03-2023), thereby attracting the statutory immunity from penalty. Consequentially the appeal is allowed and the levy of penalty under s.270A(2) is set aside.
ITAT held that the penalty under s.270A(2) for underreporting was unsustainable and directed its deletion where the assessee, during scrutiny for AY 2020-21, surrendered an incorrect deduction for education cess in light of the retrospective amendment to s.40(a)(ii) effected by Finance Act 2022. The Tribunal found the assessee complied with the proviso to s.155(18) by honestly surrendering the claim and paying tax within the statutory window (to 31-03-2023), thereby attracting the statutory immunity from penalty. Consequentially the appeal is allowed and the levy of penalty under s.270A(2) is set aside.
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TaxTMI 
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