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 dominant issue was whether TDS credit could be restricted while processing the return under section 143(1) despite the TDS appearing in Form 26AS. The appellate authority held that credit under section 199 read with Rule 37BA must be granted in accordance with verified TDS and its linkage to income corresponding to the gross receipts, and therefore directed the AO to verify these conditions and allow full TDS credit as reflected in Form 26AS upon such verification. Consequently, the Revenue's challenge was rejected and the appeal was dismissed. - ITAT
The dominant issue was whether TDS credit could be restricted while processing the return under section 143(1) despite the TDS appearing in Form 26AS. The appellate authority held that credit under section 199 read with Rule 37BA must be granted in accordance with verified TDS and its linkage to income corresponding to the gross receipts, and therefore directed the AO to verify these conditions and allow full TDS credit as reflected in Form 26AS upon such verification. Consequently, the Revenue's challenge was rejected and the appeal was dismissed. - ITAT
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TaxTMI 
TaxTMI 
of 4918 
