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...
Routine administrative and operational expenses were held allowable where the record contained no specific adverse finding that the expenditure was false or non-genuine. Disallowance based only on minimal business activity or an allegation that the entities were shell concerns was treated as perverse on the facts. The accepted genuineness of statutory and compliance-related expenses also supported the existence of normal operational costs, so the sustained disallowance of salary, rent, travelling, conveyance, telephone and similar business expenses was deleted. Interest under the consequential challenge was left to follow the main result.
Routine administrative and operational expenses were held allowable where the record contained no specific adverse finding that the expenditure was false or non-genuine. Disallowance based only on minimal business activity or an allegation that the entities were shell concerns was treated as perverse on the facts. The accepted genuineness of statutory and compliance-related expenses also supported the existence of normal operational costs, so the sustained disallowance of salary, rent, travelling, conveyance, telephone and similar business expenses was deleted. Interest under the consequential challenge was left to follow the main result.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
