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...
ITAT refused to condone a 1023-day delay in filing the quantum appeal, holding that a conscious decision not to pursue the statutory remedy after weighing tax effect and litigation cost was not sufficient cause. The quantum appeal was therefore dismissed as time-barred without examining the merits. On penalty, the Tribunal held that disallowance of a CSR-related donation claim under section 80G did not by itself establish misreporting under section 270A. As no suppression of facts, false entries, or fabricated evidence was found, and the assessee had disclosed all primary facts, the explanation was bona fide and protected by section 270A(6)(a). The penalty was deleted.
ITAT refused to condone a 1023-day delay in filing the quantum appeal, holding that a conscious decision not to pursue the statutory remedy after weighing tax effect and litigation cost was not sufficient cause. The quantum appeal was therefore dismissed as time-barred without examining the merits. On penalty, the Tribunal held that disallowance of a CSR-related donation claim under section 80G did not by itself establish misreporting under section 270A. As no suppression of facts, false entries, or fabricated evidence was found, and the assessee had disclosed all primary facts, the explanation was bona fide and protected by section 270A(6)(a). The penalty was deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
