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...
Interest on customers' fixed deposits was held deductible because the taxpayer produced contemporaneous evidence of deposits and TDS, and mere absence of payee-side acknowledgement could not justify disallowance; deletion was sustained. Disallowance under s.14A r.w. Rule 8D was held inapplicable as the investments were maintained for SLR/CRR as stock-in-trade, following binding precedent; deletion was sustained. Depreciation on temporary wooden structures and software expenditure were treated as allowable (as per consistency with earlier years); disallowances were rejected. Inter-office adjustment provision was treated as an allowable anticipated liability supported by material, not a contingent/non-existent liability; disallowance was rejected. Deduction u/s 36(1)(viia) was directed to be allowed on total provision (rural and non-rural). Depreciation on G-Secs, HTM premium amortization loss, and provision for non-performing investments were allowed. - ITAT
Interest on customers' fixed deposits was held deductible because the taxpayer produced contemporaneous evidence of deposits and TDS, and mere absence of payee-side acknowledgement could not justify disallowance; deletion was sustained. Disallowance under s.14A r.w. Rule 8D was held inapplicable as the investments were maintained for SLR/CRR as stock-in-trade, following binding precedent; deletion was sustained. Depreciation on temporary wooden structures and software expenditure were treated as allowable (as per consistency with earlier years); disallowances were rejected. Inter-office adjustment provision was treated as an allowable anticipated liability supported by material, not a contingent/non-existent liability; disallowance was rejected. Deduction u/s 36(1)(viia) was directed to be allowed on total provision (rural and non-rural). Depreciation on G-Secs, HTM premium amortization loss, and provision for non-performing investments were allowed. - ITAT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
