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 allows relief to the assessee in part and against the Revenue in part. Depreciation on electrical fittings is confirmed at 10% (not 15%), treating such installations as "furniture and fittings." Addition for foreign-exchange loss allocated by turnover is deleted and CIT(A)'s reversal is restored where losses are identifiable and claimed on actuals. Disallowance under s.40(a)(ia) is negated: late deposit of TDS where tax is deposited before the return filing due date is not disallowable, and CIT(A)'s curative-construction is affirmed. Apportionment of R&D expenses to EOUs is deleted, where the assessee had booked R&D costs to those units. AO's pre-set-off of carried-forward business loss prior to granting s.10B deduction is disapproved and CIT(A)'s treatment is upheld.
ITAT allows relief to the assessee in part and against the Revenue in part. Depreciation on electrical fittings is confirmed at 10% (not 15%), treating such installations as "furniture and fittings." Addition for foreign-exchange loss allocated by turnover is deleted and CIT(A)'s reversal is restored where losses are identifiable and claimed on actuals. Disallowance under s.40(a)(ia) is negated: late deposit of TDS where tax is deposited before the return filing due date is not disallowable, and CIT(A)'s curative-construction is affirmed. Apportionment of R&D expenses to EOUs is deleted, where the assessee had booked R&D costs to those units. AO's pre-set-off of carried-forward business loss prior to granting s.10B deduction is disapproved and CIT(A)'s treatment is upheld.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
