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...
The ITAT allowed the assessee's appeal in part, holding that interest under s.234B cannot be levied beyond the date on which the tax liability was discharged (30.04.2023); accordingly, excess interest computed by the CPC up to the date of processing of the return was directed to be deleted. The Tribunal affirmed the CIT(A)'s conclusion that a particular payment had been correctly characterized by the CPC as a payment under s.140B(1) of the Act, finding no infirmity in that determination; that aspect of the assessment was therefore upheld against the assessee and in favor of the Revenue.
The ITAT allowed the assessee's appeal in part, holding that interest under s.234B cannot be levied beyond the date on which the tax liability was discharged (30.04.2023); accordingly, excess interest computed by the CPC up to the date of processing of the return was directed to be deleted. The Tribunal affirmed the CIT(A)'s conclusion that a particular payment had been correctly characterized by the CPC as a payment under s.140B(1) of the Act, finding no infirmity in that determination; that aspect of the assessment was therefore upheld against the assessee and in favor of the Revenue.
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