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 the appeal of the assessee (an AOP), held that receipts characterised as donations returned to the entity did not attract exclusion under principles of mutuality, and directed the AO to delete the disallowances and additions. The Tribunal found the assessee's dominant activity (petrol bunk business) involved sales to members and non-members, discounts/rebates constituted ordinary business expenditure and were allowable under the tax law when net profit was offered to tax. The Tribunal rejected the AO's recharacterisation and reassessment under jurisdictional review, concluded there was identity between contributors and beneficiaries, distinguished the contrary authority, and upheld the assessee's return of income.
ITAT allowed the appeal of the assessee (an AOP), held that receipts characterised as donations returned to the entity did not attract exclusion under principles of mutuality, and directed the AO to delete the disallowances and additions. The Tribunal found the assessee's dominant activity (petrol bunk business) involved sales to members and non-members, discounts/rebates constituted ordinary business expenditure and were allowable under the tax law when net profit was offered to tax. The Tribunal rejected the AO's recharacterisation and reassessment under jurisdictional review, concluded there was identity between contributors and beneficiaries, distinguished the contrary authority, and upheld the assessee's return of income.
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