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...
In assessment u/s 153C, disallowance of depreciation on alleged bogus power-plant cost was deleted because the addition rested only on retracted oral statements, with no corroborative seized material linking alleged subcontractors to cash generation or showing incriminating material relatable to the relevant AY; proceedings could not be sustained on assumptions, so the revenue's grounds failed. Disallowance u/s 2(24)(x) r.w.s. 36(1)(va) for employees' PF contribution was directed to be deleted if bank balance existed and delay was solely due to technical glitches, subject to AO verification. Depreciation on new assets put to use in March was remanded to AO for fresh verification of purchase/use evidence. Reduction in insurance claim was sustained as duly supported. Depreciation on WDV of the power plant was allowed on consistency where no change in facts was shown. - ITAT
In assessment u/s 153C, disallowance of depreciation on alleged bogus power-plant cost was deleted because the addition rested only on retracted oral statements, with no corroborative seized material linking alleged subcontractors to cash generation or showing incriminating material relatable to the relevant AY; proceedings could not be sustained on assumptions, so the revenue's grounds failed. Disallowance u/s 2(24)(x) r.w.s. 36(1)(va) for employees' PF contribution was directed to be deleted if bank balance existed and delay was solely due to technical glitches, subject to AO verification. Depreciation on new assets put to use in March was remanded to AO for fresh verification of purchase/use evidence. Reduction in insurance claim was sustained as duly supported. Depreciation on WDV of the power plant was allowed on consistency where no change in facts was shown. - ITAT
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TaxTMI 
TaxTMI 
of 4918 
