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 motor accident compensation kept in a court-ordered fixed deposit under lien, pending challenge to the award, was held not taxable in the relevant year because the assessee neither received nor had any enforceable right to the interest amount. Applying ss. 56(2)(viii) and 145B(1), only interest "received" on compensation/enhanced compensation is deemed income of the year of receipt, not on accrual or on a hypothetical basis; hence neither substantive nor protective addition could stand. Consequentially, credit of TDS reflected against such interest was directed to be allowed to the assessee. - ITAT
Interest on motor accident compensation kept in a court-ordered fixed deposit under lien, pending challenge to the award, was held not taxable in the relevant year because the assessee neither received nor had any enforceable right to the interest amount. Applying ss. 56(2)(viii) and 145B(1), only interest "received" on compensation/enhanced compensation is deemed income of the year of receipt, not on accrual or on a hypothetical basis; hence neither substantive nor protective addition could stand. Consequentially, credit of TDS reflected against such interest was directed to be allowed to the assessee. - ITAT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
