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...
Unpaid bonus provisions are disallowable in the year of claim where payment conditions are not met, but the same income cannot be taxed again when an excess provision is reversed and offered in a later year; any resulting double taxation must be avoided through verification and reduction. Provisions made by a co-operative bank against standard assets were treated as deductible, resulting in deletion of the related disallowances. A separate disallowance of income-tax provision was deleted because the amount had already been added back, preventing double addition. Ex gratia employee incentives were treated as salary or incentive payments allowable in the year of payment. Carry-forward depreciation was directed to be recomputed.
Unpaid bonus provisions are disallowable in the year of claim where payment conditions are not met, but the same income cannot be taxed again when an excess provision is reversed and offered in a later year; any resulting double taxation must be avoided through verification and reduction. Provisions made by a co-operative bank against standard assets were treated as deductible, resulting in deletion of the related disallowances. A separate disallowance of income-tax provision was deleted because the amount had already been added back, preventing double addition. Ex gratia employee incentives were treated as salary or incentive payments allowable in the year of payment. Carry-forward depreciation was directed to be recomputed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
