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...
Disallowance of interest was contested on the ground that short-term borrowings were used for long-term investment and only a limited period of capitalization was warranted. Relying on the audit report evidencing diversion of short-term loans to capital projects already put to use, and noting that capital work-in-progress was undisputed, the appellate authority correctly sustained capitalization of interest only for four months and deleted the balance disallowance; the revenue's challenge was rejected. On transfer pricing for sugar exports, CUP-based benchmarking using FOB-converted prices with an average of NYBOT and Kingsman rates, along with the statutory tolerance range under section 92C(2), was upheld; no interference was warranted. On ferrous exports, contracts were accepted as CUP and adjustment restricted; the revenue's ground failed. - ITAT
Disallowance of interest was contested on the ground that short-term borrowings were used for long-term investment and only a limited period of capitalization was warranted. Relying on the audit report evidencing diversion of short-term loans to capital projects already put to use, and noting that capital work-in-progress was undisputed, the appellate authority correctly sustained capitalization of interest only for four months and deleted the balance disallowance; the revenue's challenge was rejected. On transfer pricing for sugar exports, CUP-based benchmarking using FOB-converted prices with an average of NYBOT and Kingsman rates, along with the statutory tolerance range under section 92C(2), was upheld; no interference was warranted. On ferrous exports, contracts were accepted as CUP and adjustment restricted; the revenue's ground failed. - ITAT
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TaxTMI 
TaxTMI 
of 4918 
