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...
Common area maintenance recoveries treated as business income supported allowance of related expenditure, and proportionate disallowance by reference to house property income was rejected where the assessee was contractually responsible only for common areas of the mall. Repairs and maintenance, legal and professional fees, employee remuneration, advertisement and sales promotion, and security charges were each held to be linked to mall management and CAM obligations rather than to rental income, subject only to limited factual restriction in respect of office and general expenses. The Tribunal also upheld the appellate authority's power to entertain and direct verification of an additional property tax deduction claim arising from the record.
Common area maintenance recoveries treated as business income supported allowance of related expenditure, and proportionate disallowance by reference to house property income was rejected where the assessee was contractually responsible only for common areas of the mall. Repairs and maintenance, legal and professional fees, employee remuneration, advertisement and sales promotion, and security charges were each held to be linked to mall management and CAM obligations rather than to rental income, subject only to limited factual restriction in respect of office and general expenses. The Tribunal also upheld the appellate authority's power to entertain and direct verification of an additional property tax deduction claim arising from the record.
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