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...
Insurance premium written back under extraordinary items required verification of whether the original disallowance of the larger amount had survived in appeal, and the balance addition was remitted for consequential recomputation after checking that status. Foreign exchange fluctuation loss was treated as a loss that crystallised only in the subsequent year when payment was made at a higher exchange rate, so it was regarded as an unascertained liability on the balance-sheet date and the disallowance, including the book profit add-back, was sustained. Prior period expenditure, including interest to financial institutions, was allowed in the year of payment where the liability had crystallised, and the corresponding disallowance was deleted.
Insurance premium written back under extraordinary items required verification of whether the original disallowance of the larger amount had survived in appeal, and the balance addition was remitted for consequential recomputation after checking that status. Foreign exchange fluctuation loss was treated as a loss that crystallised only in the subsequent year when payment was made at a higher exchange rate, so it was regarded as an unascertained liability on the balance-sheet date and the disallowance, including the book profit add-back, was sustained. Prior period expenditure, including interest to financial institutions, was allowed in the year of payment where the liability had crystallised, and the corresponding disallowance was deleted.
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