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...
TDR expenditure treated as inventory cost was held allowable in the year to which the AO had himself earlier attributed it; having disallowed it as "prior period" in a later year on the footing that it pertained to the earlier year, the revenue could not take a contradictory stand to deny deduction in both years. The reassessment disallowance was therefore directed to be deleted. Penalty under s. 270A on disallowance of Keyman insurance premium was deleted because the issue was debatable and the AO failed to record the requisite finding specifying whether the case involved under-reporting or misreporting. Disallowance of interest under s. 36(1)(iii) on interest-free advances was deleted since interest-free funds exceeded the advances, attracting the presumption that advances were from such funds - ITAT
TDR expenditure treated as inventory cost was held allowable in the year to which the AO had himself earlier attributed it; having disallowed it as "prior period" in a later year on the footing that it pertained to the earlier year, the revenue could not take a contradictory stand to deny deduction in both years. The reassessment disallowance was therefore directed to be deleted. Penalty under s. 270A on disallowance of Keyman insurance premium was deleted because the issue was debatable and the AO failed to record the requisite finding specifying whether the case involved under-reporting or misreporting. Disallowance of interest under s. 36(1)(iii) on interest-free advances was deleted since interest-free funds exceeded the advances, attracting the presumption that advances were from such funds - ITAT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
