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...
Admission of additional evidence under Rule 29 of ITAT Rules was allowed and admitted. Non-deduction of tax at source was considered: for two payees, production and departmental verification of TDS certificates established that the assessee is not in default, and the demand under section 201(1) and interest under section 201(1A) relating to those payments were deleted. For two other payees, a 30% disallowance of expenditure for non-deduction was upheld and the Assessing Officer was directed to recompute any liability accordingly. Verification of TDS return filing was ordered and fee under section 234E to be deleted if return was timely.
Admission of additional evidence under Rule 29 of ITAT Rules was allowed and admitted. Non-deduction of tax at source was considered: for two payees, production and departmental verification of TDS certificates established that the assessee is not in default, and the demand under section 201(1) and interest under section 201(1A) relating to those payments were deleted. For two other payees, a 30% disallowance of expenditure for non-deduction was upheld and the Assessing Officer was directed to recompute any liability accordingly. Verification of TDS return filing was ordered and fee under section 234E to be deleted if return was timely.
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TaxTMI 
TaxTMI 
of 4918 
