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...
ITAT held that the assessee failed to discharge the onus of substantiating its claims of expenditure on service fees paid to KMCCL and legal fees paid to M/s CAM, as no enforceable agreements, correspondence, or supporting documents were produced before the lower authorities. However, considering that the issues had not been adjudicated with complete evidence, ITAT remanded both issues to the Commissioner for de novo adjudication. The Commissioner is directed to reconsider the disallowances after affording a reasonable opportunity of hearing, while the assessee is directed to file all relevant agreements and communications, failing which no leniency shall be extended regarding the claimed deductions.
ITAT held that the assessee failed to discharge the onus of substantiating its claims of expenditure on service fees paid to KMCCL and legal fees paid to M/s CAM, as no enforceable agreements, correspondence, or supporting documents were produced before the lower authorities. However, considering that the issues had not been adjudicated with complete evidence, ITAT remanded both issues to the Commissioner for de novo adjudication. The Commissioner is directed to reconsider the disallowances after affording a reasonable opportunity of hearing, while the assessee is directed to file all relevant agreements and communications, failing which no leniency shall be extended regarding the claimed deductions.
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TaxTMI 
TaxTMI 
of 4918 
