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 allowed the assessee-bank's claim for deduction of amortization of premium paid on purchase of government securities held under the HTM category. It held that the assessee, engaged in banking business under the Banking Regulation Act, 1949 and Regional Rural Banks Act, 1976, is statutorily required to invest in government securities to maintain SLR and capital adequacy norms prescribed by RBI. The Tribunal treated the premium amortized over the period to maturity as revenue expenditure, following its earlier precedent, and held that such amortization is an allowable deduction in computing taxable income. The Revenue's objections were consequently rejected.
ITAT allowed the assessee-bank's claim for deduction of amortization of premium paid on purchase of government securities held under the HTM category. It held that the assessee, engaged in banking business under the Banking Regulation Act, 1949 and Regional Rural Banks Act, 1976, is statutorily required to invest in government securities to maintain SLR and capital adequacy norms prescribed by RBI. The Tribunal treated the premium amortized over the period to maturity as revenue expenditure, following its earlier precedent, and held that such amortization is an allowable deduction in computing taxable income. The Revenue's objections were consequently rejected.
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TaxTMI 
TaxTMI 
of 4918 
