https://www.taxtmi.com/caselaws?id=311519 The ITAT Chennai upheld the CIT(A)'s decision allowing management fees paid to India Offshore Inc., finding the payments genuine and commercially expedient based on approved agreements and consistent with earlier assessment years. The tribunal rejected the assessee's challenge to reassessment validity, holding that notices issued within the prescribed six-year limit remain valid even on the last day. Regarding forex losses, the tribunal remanded the matter to AO for verification of whether losses related to asset acquisition or revenue transactions. The TDS disallowance issue was also remanded for reconsideration following previous tribunal decisions. The depreciation disallowance on forex differences was set aside for AO re-examination of evidence. The tribunal rejected revenue's challenge regarding CIT(A)'s powers, finding no Rule 46A violation. en-us Wed, 06 Apr 2022 00:00:00 +0530 Sat, 30 Dec 2023 08:30:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=311519 The ITAT Chennai upheld the CIT(A)'s decision allowing management fees paid to India Offshore Inc., finding the payments genuine and commercially expedient based on approved agreements and consistent with earlier assessment years. The tribunal rejected the assessee's challenge to reassessment validity, holding that notices issued within the prescribed six-year limit remain valid even on the last day. Regarding forex losses, the tribunal remanded the matter to AO for verification of whether losses related to asset acquisition or revenue transactions. The TDS disallowance issue was also remanded for reconsideration following previous tribunal decisions. The depreciation disallowance on forex differences was set aside for AO re-examination of evidence. The tribunal rejected revenue's challenge regarding CIT(A)'s powers, finding no Rule 46A violation. Case-Laws Income Tax Wed, 06 Apr 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=311519