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...
Medical reimbursement and incidental travel expenses of the Chairman were held allowable as business expenditure because the board-approved service terms specifically permitted reimbursement and the business nexus was accepted. The Tribunal also set aside rejection of the Sahibabad unit's books and the estimated profit addition, finding that the assessment rested only on that unit's loss, without any specific defect in the accounts, under-reporting of receipts, or proved inflation of expenditure. The assessee's explanation that the Jaipur and Sahibabad units functioned in a combined manner was not properly considered.
Medical reimbursement and incidental travel expenses of the Chairman were held allowable as business expenditure because the board-approved service terms specifically permitted reimbursement and the business nexus was accepted. The Tribunal also set aside rejection of the Sahibabad unit's books and the estimated profit addition, finding that the assessment rested only on that unit's loss, without any specific defect in the accounts, under-reporting of receipts, or proved inflation of expenditure. The assessee's explanation that the Jaipur and Sahibabad units functioned in a combined manner was not properly considered.
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