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...
Adjustment under s.143(1)(a) reducing depreciation on goods carriage vehicles from 30% to 15% was invalid because only arithmetical errors or incorrect claims apparent from the return can be adjusted, whereas the applicable depreciation rate is a debatable matter requiring examination beyond the limited, mechanical scope of processing. On merits, higher depreciation at 30% was allowable for goods carriage vehicles run on hire, including vehicles used in the assessee's transportation business for carrying goods on hire, consistent with settled law. Consequently, the disallowance/addition made while processing the return was directed to be deleted and the appeal was allowed. - ITAT
Adjustment under s.143(1)(a) reducing depreciation on goods carriage vehicles from 30% to 15% was invalid because only arithmetical errors or incorrect claims apparent from the return can be adjusted, whereas the applicable depreciation rate is a debatable matter requiring examination beyond the limited, mechanical scope of processing. On merits, higher depreciation at 30% was allowable for goods carriage vehicles run on hire, including vehicles used in the assessee's transportation business for carrying goods on hire, consistent with settled law. Consequently, the disallowance/addition made while processing the return was directed to be deleted and the appeal was allowed. - ITAT
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TaxTMI 
TaxTMI 
of 4921 
