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...
Depreciation on vehicles under operating leases is discussed in relation to ownership where registration certificates stand in customers' names. Master Lease Agreements may establish the lessor's ownership and customers' limited right of use; registration and lessee use do not, by themselves, displace depreciation eligibility. The text also addresses an undecided ground concerning deferred maintenance charges, noting that where a specifically raised ground has not been determined, it requires limited fresh consideration. It describes depreciation questions as not raising a substantial question of law and the maintenance-charge issue as remanded for determination.
Depreciation on vehicles under operating leases is discussed in relation to ownership where registration certificates stand in customers' names. Master Lease Agreements may establish the lessor's ownership and customers' limited right of use; registration and lessee use do not, by themselves, displace depreciation eligibility. The text also addresses an undecided ground concerning deferred maintenance charges, noting that where a specifically raised ground has not been determined, it requires limited fresh consideration. It describes depreciation questions as not raising a substantial question of law and the maintenance-charge issue as remanded for determination.
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