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...
Actuarially determined provision for accumulated non-encashable sick leave constitutes an accrued employee-benefit liability where employees earn paid future leave through services rendered during the relevant year. The employer's obligation to grant paid absence when leave is used remains a financial obligation, despite no employee right to receive cash for unused leave. Uncertainty over the employee or timing of future utilisation does not make a scientifically estimated liability contingent. As no payment is made in lieu of leave, leave-encashment payment conditions do not apply. The provision is deductible as an accrued business liability, and the disallowance was deleted.
Actuarially determined provision for accumulated non-encashable sick leave constitutes an accrued employee-benefit liability where employees earn paid future leave through services rendered during the relevant year. The employer's obligation to grant paid absence when leave is used remains a financial obligation, despite no employee right to receive cash for unused leave. Uncertainty over the employee or timing of future utilisation does not make a scientifically estimated liability contingent. As no payment is made in lieu of leave, leave-encashment payment conditions do not apply. The provision is deductible as an accrued business liability, and the disallowance was deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
