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 DRP directions and restored the file to the DRP for fresh consideration, holding that the DRP's order was ambiguous, factually confused and failed to address the core dispute on characterization of charter hire receipts (royalty v. presumptive income under s.44BB). The Tribunal observed the DRP erroneously discussed DTAA applicability and reopening under s.147 despite this being a normal assessment under s.143(3). ITAT directed the DRP to re-examine all issues raised by the assessee, afford the assessee a hearing, and issue clear, speaking directions to the AO to enable adjudication on merits.
ITAT set aside the DRP directions and restored the file to the DRP for fresh consideration, holding that the DRP's order was ambiguous, factually confused and failed to address the core dispute on characterization of charter hire receipts (royalty v. presumptive income under s.44BB). The Tribunal observed the DRP erroneously discussed DTAA applicability and reopening under s.147 despite this being a normal assessment under s.143(3). ITAT directed the DRP to re-examine all issues raised by the assessee, afford the assessee a hearing, and issue clear, speaking directions to the AO to enable adjudication on merits.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
