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...
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The ITAT deleted transfer-pricing adjustments in respect of AMP expenses and royalty payments and directed deletion of TP adjustments to service fees, applying the co-ordinate bench precedent and allowing the assessee's appeals on those issues. An ad hoc TP adjustment to global services was disallowed and the regional service fee challenge was allowed in favour of the assessee. The Tribunal remitted the Section 14A/read with Rule 8D disallowance to the AO for re-adjudication in light of the assessee's suo-moto salary disallowance. Allocation-related disallowances for Unit-I and Unit-II were deleted and relevant grounds allowed. Issues as to interest under s.234C and MAT credit were remitted to the AO for recomputation and adjudication.
The ITAT deleted transfer-pricing adjustments in respect of AMP expenses and royalty payments and directed deletion of TP adjustments to service fees, applying the co-ordinate bench precedent and allowing the assessee's appeals on those issues. An ad hoc TP adjustment to global services was disallowed and the regional service fee challenge was allowed in favour of the assessee. The Tribunal remitted the Section 14A/read with Rule 8D disallowance to the AO for re-adjudication in light of the assessee's suo-moto salary disallowance. Allocation-related disallowances for Unit-I and Unit-II were deleted and relevant grounds allowed. Issues as to interest under s.234C and MAT credit were remitted to the AO for recomputation and adjudication.
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