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...
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Eligibility for deduction U/s.11 & 12 - The claim of the assessee to carry forward the excess application of fund cannot be entertained applying the commercial principles. However if the excess application of funds are from the borrowed fund or from the sundry creditors during the earlier years, the same shall be allowed as application in the year in which such loan or sundry creditors are repaid from the income of the trust. - AT
Eligibility for deduction U/s.11 & 12 - The claim of the assessee to carry forward the excess application of fund cannot be entertained applying the commercial principles. However if the excess application of funds are from the borrowed fund or from the sundry creditors during the earlier years, the same shall be allowed as application in the year in which such loan or sundry creditors are repaid from the income of the trust. - AT
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