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 CIT(A)'s deletion of the transfer pricing upward adjustment by the AO, finding no infirmity in treating the deleted clause (i) of section 92BA as never having existed following its omission by the Finance Act, 2017, and thereby rejecting Revenue's grounds. The Tribunal agreed that the TPO's adoption of the internal CUP as MAM and the AO's reliance on the erstwhile provision did not sustain the addition. Further, ITAT deleted the penalty under section 271AA imposed for non-maintenance of records relating to specified domestic transactions. The appeals filed by the Revenue were dismissed, and the assessment adjustments and penalty were quashed.
ITAT upheld the CIT(A)'s deletion of the transfer pricing upward adjustment by the AO, finding no infirmity in treating the deleted clause (i) of section 92BA as never having existed following its omission by the Finance Act, 2017, and thereby rejecting Revenue's grounds. The Tribunal agreed that the TPO's adoption of the internal CUP as MAM and the AO's reliance on the erstwhile provision did not sustain the addition. Further, ITAT deleted the penalty under section 271AA imposed for non-maintenance of records relating to specified domestic transactions. The appeals filed by the Revenue were dismissed, and the assessment adjustments and penalty were quashed.
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