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...
Disallowance of commission paid to directors - allegation that commission was paid to avoid dividend distribution tax - there being no nexus between the two payments i.e., commission and dividend to the directors, the disallowance made could not have been sustained. - AT
Disallowance of commission paid to directors - allegation that commission was paid to avoid dividend distribution tax - there being no nexus between the two payments i.e., commission and dividend to the directors, the disallowance made could not have been sustained. - AT
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