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 allowed deduction under sec.43B for amounts paid in the relevant FY and directed deletion of service tax payment of Rs.1,40,23,520 and disallowance relating to TDS, finding these were paid in the FY relevant to AY 2018-19 and reflected in ITR-6 and audit reports; it sustained disallowance of Rs.1,03,93,805 for unpaid liabilities where supporting challans/evidence were not produced. ITAT set aside the CIT(A) order and remitted the matter to the AO to give effect to these findings, delete the specified additions, and to modify penalty proceedings under sec.270A accordingly after recalculation in light of the allowed reliefs.
ITAT allowed deduction under sec.43B for amounts paid in the relevant FY and directed deletion of service tax payment of Rs.1,40,23,520 and disallowance relating to TDS, finding these were paid in the FY relevant to AY 2018-19 and reflected in ITR-6 and audit reports; it sustained disallowance of Rs.1,03,93,805 for unpaid liabilities where supporting challans/evidence were not produced. ITAT set aside the CIT(A) order and remitted the matter to the AO to give effect to these findings, delete the specified additions, and to modify penalty proceedings under sec.270A accordingly after recalculation in light of the allowed reliefs.
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