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 upheld the AO's disallowance of deductions claimed as "impairment of assets" and "abnormal loss" on spares, holding such amounts relate to depreciable fixed assets and are not allowable as revenue expenditure; the Tribunal directed the AO to permit adjustment of those amounts in the relevant block of assets and to allow consequent depreciation. Concurrently, ITAT quashed the penalty under section 270A for misreporting, finding no misrepresentation, suppression, false entry or unsupported claim, and noting absence of requisite findings by the AO; grounds challenging the disallowance were dismissed while the penalty was cancelled.
ITAT upheld the AO's disallowance of deductions claimed as "impairment of assets" and "abnormal loss" on spares, holding such amounts relate to depreciable fixed assets and are not allowable as revenue expenditure; the Tribunal directed the AO to permit adjustment of those amounts in the relevant block of assets and to allow consequent depreciation. Concurrently, ITAT quashed the penalty under section 270A for misreporting, finding no misrepresentation, suppression, false entry or unsupported claim, and noting absence of requisite findings by the AO; grounds challenging the disallowance were dismissed while the penalty was cancelled.
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TaxTMI 
TaxTMI 
of 4918 
