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 allowed the appeal of the Appellant and set aside the ad-hoc disallowance of travelling and conveyance expenditure imposed by the AO and sustained by the CIT(A), holding that ad-hoc disallowance is impermissible where business necessity and bona fide reimbursement practice are established. The Tribunal found the expenditure-largely employee reimbursements for medical-representative travel-was a legitimate business expense, supported by employee declarations, an approvals system and audited books with no adverse findings; even alleged excess reimbursements, if bona fide, remain deductible in the hands of the assessee. Grounds of the Appellant were sustained and Revenue's disallowance was rejected.
ITAT allowed the appeal of the Appellant and set aside the ad-hoc disallowance of travelling and conveyance expenditure imposed by the AO and sustained by the CIT(A), holding that ad-hoc disallowance is impermissible where business necessity and bona fide reimbursement practice are established. The Tribunal found the expenditure-largely employee reimbursements for medical-representative travel-was a legitimate business expense, supported by employee declarations, an approvals system and audited books with no adverse findings; even alleged excess reimbursements, if bona fide, remain deductible in the hands of the assessee. Grounds of the Appellant were sustained and Revenue's disallowance was rejected.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
