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 set aside the reassessment as invalid and quashed the proceedings under s.147/148 where the AO, without issuing a fresh notice under s.148, sustained an addition on a ground different from the reasons recorded for reopening. The Tribunal held that the reassessment was vitiated for lack of jurisdictional compliance. On merits, the Tribunal allowed the assessee's claim for bad debts written off in the profit and loss account, accepting that export receivables remained irrecoverable despite bona fide recovery efforts; any subsequent realizations are to be offered to tax in the year of receipt. The assessee's appeal is allowed and the impugned assessment order is set aside.
ITAT set aside the reassessment as invalid and quashed the proceedings under s.147/148 where the AO, without issuing a fresh notice under s.148, sustained an addition on a ground different from the reasons recorded for reopening. The Tribunal held that the reassessment was vitiated for lack of jurisdictional compliance. On merits, the Tribunal allowed the assessee's claim for bad debts written off in the profit and loss account, accepting that export receivables remained irrecoverable despite bona fide recovery efforts; any subsequent realizations are to be offered to tax in the year of receipt. The assessee's appeal is allowed and the impugned assessment order is set aside.
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