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 upholds that TP adjustments in respect of international transactions for export of finished goods and royalty payments to an AE are deleted: ALP may be benchmarked by TNMM where CUP is inappropriate due to factual/geographical differences, following a co-ordinate bench decision in the assessee's own case. The tribunal directs rectification of an inadvertent addition of TP adjustments in the computation of book profit under s.115JB to align with the final order. Claims for credit under s.115JAA and TDS are remitted to the AO for verification and appropriate grant. Interest under s.234C is to be computed on returned income after accounting taxes paid. Deduction u/s.80G for donations from CSR funds is allowed where statutory conditions are satisfied.
ITAT upholds that TP adjustments in respect of international transactions for export of finished goods and royalty payments to an AE are deleted: ALP may be benchmarked by TNMM where CUP is inappropriate due to factual/geographical differences, following a co-ordinate bench decision in the assessee's own case. The tribunal directs rectification of an inadvertent addition of TP adjustments in the computation of book profit under s.115JB to align with the final order. Claims for credit under s.115JAA and TDS are remitted to the AO for verification and appropriate grant. Interest under s.234C is to be computed on returned income after accounting taxes paid. Deduction u/s.80G for donations from CSR funds is allowed where statutory conditions are satisfied.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
