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...
The ITAT set aside the impugned disallowances and allowed the claimed deductions. The tribunal deleted the disallowance under s.14A r.w.r.8D, applying the principle that major expenditures must correlate with exempt income. Disallowances of brokerage payments were held to be ordinary course business expenses for entities engaged in commercial property leasing and were deleted where TDS evidence was furnished. Denial of deduction under s.80IAB for car-parking rental income was reversed, the tribunal finding no distinguishing facts to deny the incentive. Settlement fees paid on premature termination of service contracts were characterized as revenue expenditure incurred for commercial expediency (not capital acquisition) and allowed. The ITAT therefore ruled in favour of the assessee on the contested adjustments.
The ITAT set aside the impugned disallowances and allowed the claimed deductions. The tribunal deleted the disallowance under s.14A r.w.r.8D, applying the principle that major expenditures must correlate with exempt income. Disallowances of brokerage payments were held to be ordinary course business expenses for entities engaged in commercial property leasing and were deleted where TDS evidence was furnished. Denial of deduction under s.80IAB for car-parking rental income was reversed, the tribunal finding no distinguishing facts to deny the incentive. Settlement fees paid on premature termination of service contracts were characterized as revenue expenditure incurred for commercial expediency (not capital acquisition) and allowed. The ITAT therefore ruled in favour of the assessee on the contested adjustments.
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TaxTMI 
TaxTMI 
of 4918 
