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...
ITAT upheld the assessee's accounting treatment, disallowing the tax authorities' rejection of lease equalization charges and related depreciation adjustments. The Tribunal found the assessee had consistently followed the ICAI Guidelines on accounting for leases, separately disclosing lease rentals and matching lease annual charges in the profit and loss account; where annual lease charges fell below minimum statutory depreciation the excess was claimed as expenditure, to be reversed or credited when annual charges exceed statutory depreciation. As a regularly followed, declared accounting policy producing revenue neutrality across assessment years, the treatment is acceptable for tax purposes. Accordingly, the contested grounds were allowed and the disallowances set aside.
ITAT upheld the assessee's accounting treatment, disallowing the tax authorities' rejection of lease equalization charges and related depreciation adjustments. The Tribunal found the assessee had consistently followed the ICAI Guidelines on accounting for leases, separately disclosing lease rentals and matching lease annual charges in the profit and loss account; where annual lease charges fell below minimum statutory depreciation the excess was claimed as expenditure, to be reversed or credited when annual charges exceed statutory depreciation. As a regularly followed, declared accounting policy producing revenue neutrality across assessment years, the treatment is acceptable for tax purposes. Accordingly, the contested grounds were allowed and the disallowances set aside.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
