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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Whether a transaction is shame - held that:- The existence or non-existence of written agreement would not be fatal to claim deduction on account of expenditure on account of commission. - the finding of the AO with regard to the agreement being a sham document cannot be sustained.... - AT
Whether a transaction is shame - held that:- The existence or non-existence of written agreement would not be fatal to claim deduction on account of expenditure on account of commission. - the finding of the AO with regard to the agreement being a sham document cannot be sustained.... - AT
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