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...
Disallowance u/s 40A(2)(a) – Professional fees paid to the subsidiary company - three situations, warranting disallowance u/s 40A(2), are joined by the word ‘or’ and are independent of each other - AO has not determined the fair market value - no disallowance - AT
Disallowance u/s 40A(2)(a) – Professional fees paid to the subsidiary company - three situations, warranting disallowance u/s 40A(2), are joined by the word ‘or’ and are independent of each other - AO has not determined the fair market value - no disallowance - AT
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