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...
Weighted deduction for research and development was confined to expenditure approved by the prescribed authority, but the unapproved revenue outlay retained its character as business expenditure and was allowed under general deduction principles. The Tribunal also applied the presumption that investments were made from interest-free funds where own funds exceeded investments, so the interest component of the exempt-income disallowance was deleted and the balance was to be recomputed only against investments yielding exempt income. Rent paid to related parties for a farmhouse was only partly supported by business use, so the disallowance was restricted to 50%.
Weighted deduction for research and development was confined to expenditure approved by the prescribed authority, but the unapproved revenue outlay retained its character as business expenditure and was allowed under general deduction principles. The Tribunal also applied the presumption that investments were made from interest-free funds where own funds exceeded investments, so the interest component of the exempt-income disallowance was deleted and the balance was to be recomputed only against investments yielding exempt income. Rent paid to related parties for a farmhouse was only partly supported by business use, so the disallowance was restricted to 50%.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
