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...
The ITAT dismissed the assessee's DTAA beneficial-rate challenge, following the Special Bench; held the appointed date in the amalgamation scheme is effective from 01.01.2018 so BFIL's rural advances post-that date qualify for deduction under s.36(1)(viia) with 8.5% applicable, but remitted quantum to the AO for factual verification; remitted the issue of loss on sale of property acquired in satisfaction of debt to AO to examine facts and allow as business loss; directed AO to examine and allow s.36(1)(viia) claims for provisions on standard assets; remitted additional ESOP deduction for verification; deleted s.14A disallowance; upheld allowability of QIP issue expenses under s.35D; allowed credit-card bad debts under s.36(1)(vii); sustained deduction for interest on perpetual bonds and amortisation of HTM premium; broken-period interest decision favours the assessee.
The ITAT dismissed the assessee's DTAA beneficial-rate challenge, following the Special Bench; held the appointed date in the amalgamation scheme is effective from 01.01.2018 so BFIL's rural advances post-that date qualify for deduction under s.36(1)(viia) with 8.5% applicable, but remitted quantum to the AO for factual verification; remitted the issue of loss on sale of property acquired in satisfaction of debt to AO to examine facts and allow as business loss; directed AO to examine and allow s.36(1)(viia) claims for provisions on standard assets; remitted additional ESOP deduction for verification; deleted s.14A disallowance; upheld allowability of QIP issue expenses under s.35D; allowed credit-card bad debts under s.36(1)(vii); sustained deduction for interest on perpetual bonds and amortisation of HTM premium; broken-period interest decision favours the assessee.
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