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 held: the challenge to the assessment under s.153 is kept open pending adjudication before the Hon'ble SC; AO directed to give effect to the SC outcome in the pending proceedings. Claim for deduction under s.80IA was remanded to the AO for factual verification under the second proviso to s.80IA(4) to determine whether the projects commenced development or O&M on/after 1.4.2017, precluding a conclusive appellate finding. On TP adjustments, ITAT found the specified domestic transactions benchmarked on CUP valid: where the AE passed government receipts to the assessee without mark-up under back-to-back contracts, those receipts constituted ALP; TPO's reallocation of corporate costs exceeded TP scope, so AO's TP additions were deleted.
ITAT held: the challenge to the assessment under s.153 is kept open pending adjudication before the Hon'ble SC; AO directed to give effect to the SC outcome in the pending proceedings. Claim for deduction under s.80IA was remanded to the AO for factual verification under the second proviso to s.80IA(4) to determine whether the projects commenced development or O&M on/after 1.4.2017, precluding a conclusive appellate finding. On TP adjustments, ITAT found the specified domestic transactions benchmarked on CUP valid: where the AE passed government receipts to the assessee without mark-up under back-to-back contracts, those receipts constituted ALP; TPO's reallocation of corporate costs exceeded TP scope, so AO's TP additions were deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
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