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...
Bad debt deduction is allowable where the assessee has written off the dues in its accounts as irrecoverable; under the amended law, further proof that the debt had actually become irrecoverable is not required, and the Tribunal deleted the disallowance by following T.R.F. Ltd. Estimated business expense disallowance based on fixed percentages of transportation and vehicle-related es, without comparable material or a reasoned basis, was held arbitrary and unsustainable; the 10% addition was deleted. The assessee's appeal was allowed.
Bad debt deduction is allowable where the assessee has written off the dues in its accounts as irrecoverable; under the amended law, further proof that the debt had actually become irrecoverable is not required, and the Tribunal deleted the disallowance by following T.R.F. Ltd. Estimated business expense disallowance based on fixed percentages of transportation and vehicle-related es, without comparable material or a reasoned basis, was held arbitrary and unsustainable; the 10% addition was deleted. The assessee's appeal was allowed.
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