Opportunity to furnish unsecured-loan confirmations is required before reassessment initiation; proceedings require fresh consideration after taxpayer...
Under-reporting on a first reassessment return attracts penalty, while enhanced misreporting penalty requires proof of a statutory misreporting catego...
ITAT remanded the transfer-pricing issues to the file of the AO/TPO for fresh benchmarking of international transactions, holding that key contentions raised by the assessee regarding pricing and comparability were raised for the first time on appeal and require reconsideration; grounds 2-8 were partly allowed for statistical purposes. The Tribunal directed the AO/TPO to permit interest disallowance under the proviso to s.36(1) to be treated as revenue expenditure in favour of the assessee. The Tribunal also held that contested advertisement expenditure is revenue in nature and allowed the corresponding ground of appeal.
ITAT remanded the transfer-pricing issues to the file of the AO/TPO for fresh benchmarking of international transactions, holding that key contentions raised by the assessee regarding pricing and comparability were raised for the first time on appeal and require reconsideration; grounds 2-8 were partly allowed for statistical purposes. The Tribunal directed the AO/TPO to permit interest disallowance under the proviso to s.36(1) to be treated as revenue expenditure in favour of the assessee. The Tribunal also held that contested advertisement expenditure is revenue in nature and allowed the corresponding ground of appeal.
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TaxTMI 
TaxTMI 
of 4916 
