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 expenses apportioned to rented portions was contested where corresponding recoveries (power charges and CAM/maintenance) were recorded as business income. Applying the matching principle and prior coordinate bench decisions on identical facts, the ITAT held that apportioned power and fuel expenses and proportionate repair and maintenance charges need not be disallowed when recovered from tenants and reflected as business income; accordingly the Tribunal deleted the AO's additions in respect of both categories of expenses.
Disallowance of expenses apportioned to rented portions was contested where corresponding recoveries (power charges and CAM/maintenance) were recorded as business income. Applying the matching principle and prior coordinate bench decisions on identical facts, the ITAT held that apportioned power and fuel expenses and proportionate repair and maintenance charges need not be disallowed when recovered from tenants and reflected as business income; accordingly the Tribunal deleted the AO's additions in respect of both categories of expenses.
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