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 Pr. CIT's revision under section 263, invoking Explanation 2 clause (a) to contend that CSR outlays mandated by the Companies Act, 2013 cannot form the source of donations eligible for deduction under section 80G, was unsustainable. The Tribunal found the issue settled by its coordinate benches that donations made from CSR-mandated funds may qualify for deduction under section 80G if all statutory conditions of section 80G are satisfied. Consequently, the initiation and sustaining of revisionary proceedings were based on a misconstruction of law; the order passed under section 263 was quashed and the assessee's grounds of appeal were allowed.
ITAT held that the Pr. CIT's revision under section 263, invoking Explanation 2 clause (a) to contend that CSR outlays mandated by the Companies Act, 2013 cannot form the source of donations eligible for deduction under section 80G, was unsustainable. The Tribunal found the issue settled by its coordinate benches that donations made from CSR-mandated funds may qualify for deduction under section 80G if all statutory conditions of section 80G are satisfied. Consequently, the initiation and sustaining of revisionary proceedings were based on a misconstruction of law; the order passed under section 263 was quashed and the assessee's grounds of appeal were allowed.
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TaxTMI 
TaxTMI 
of 4918 
