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 assessee's appeal and deleted the addition of Rs. 2,50,000 made by the Commissioner (Appeals) relating to the interest component of GST expenses spanning FY 2020-21 to FY 2022-23. The Tribunal held the impugned order lacked any legal rationale under the statute for disallowance and contained no explanation of the methodology or basis for estimating the aforesaid amount. Revenue failed to establish a sustainable case and the Departmental Representative did not furnish substantive legal or evidentiary assistance beyond reliance on the CIT(A)'s order. Consequently, the monetary addition was disallowed for want of legal justification and reasonable estimation, and the assessee's appeal was allowed.
ITAT allowed the assessee's appeal and deleted the addition of Rs. 2,50,000 made by the Commissioner (Appeals) relating to the interest component of GST expenses spanning FY 2020-21 to FY 2022-23. The Tribunal held the impugned order lacked any legal rationale under the statute for disallowance and contained no explanation of the methodology or basis for estimating the aforesaid amount. Revenue failed to establish a sustainable case and the Departmental Representative did not furnish substantive legal or evidentiary assistance beyond reliance on the CIT(A)'s order. Consequently, the monetary addition was disallowed for want of legal justification and reasonable estimation, and the assessee's appeal was allowed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
