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 allowed the taxpayer's appeal, holding that payments of lease rentals made to the statutory development authority during the relevant fiscal year were not subject to deduction of tax at source under section 194-I prior to the date on which higher courts declared the provision to apply prospectively. The Tribunal found that the assessing authorities erred in treating the taxpayer as an "assessee in default" and in issuing orders under sections 201(1)/201(1A). Pursuant to the appellate and superior court pronouncements giving prospective effect to TDS applicability, the orders of the lower authorities and the CIT(A) were set aside and the taxpayer's appeal was allowed.
The ITAT allowed the taxpayer's appeal, holding that payments of lease rentals made to the statutory development authority during the relevant fiscal year were not subject to deduction of tax at source under section 194-I prior to the date on which higher courts declared the provision to apply prospectively. The Tribunal found that the assessing authorities erred in treating the taxpayer as an "assessee in default" and in issuing orders under sections 201(1)/201(1A). Pursuant to the appellate and superior court pronouncements giving prospective effect to TDS applicability, the orders of the lower authorities and the CIT(A) were set aside and the taxpayer's appeal was allowed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
