The assessment based on a second notice issued in July 2022 was quashed as time-barred. Once limitation had expired, subsequent notices could not revive reassessment jurisdiction.
The ITAT ruled that customer discounts are deductible when quantified and finalised in the year of claim, even if labelled as prior-period items. The decision reinforces that timing of crystallisation outweighs book classification.
The tribunal held that advances received from customers for future services cannot be treated as unexplained cash credits. Once the assessee proves identity, nature, and business purpose, Section 68 addition fails.
The tribunal held that prior approval under Section 153D was granted mechanically without application of mind. Such invalid sanction vitiated the entire search assessment, leading to quashing of the order.
The dispute centered on whether indexation could be claimed on a factory building sold along with land. The tribunal held that once depreciation is claimed, section 50 applies, and indexation is not permissible.
The tribunal held that salary payments, even with TDS and bank transfers, require proof of genuineness and business nexus. The matter was remanded to the Assessing Officer for fresh verification of employee evidence.
The Tribunal held that AMC services and marketing support services could not be aggregated for transfer pricing purposes. It directed separate segment-wise benchmarking based on functional differences.
The Tribunal considered whether provisional customs duty payments qualify for deduction. It ruled that Section 43B permits deduction on payment basis regardless of later refunds.
The Tribunal held that once bills and vouchers are furnished, ad hoc disallowance of expenses is unjustified. Unsupported estimations without defects cannot sustain additions.
The Tribunal recognised that funds could not be used due to a High Court injunction. Such legally restrained non-utilisation cannot be treated as a statutory violation.
