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...
Deemed dividend u/s 2(22)(e) - payments effected by the Subsidiary Company and received by the Assessee, were as part of the regular business transactions - it could not have been treated as 'loan' or 'advances', so as to make the disputed amounts as “deemed dividend”, as defined under Section 2(22)(e). - HC
Deemed dividend u/s 2(22)(e) - payments effected by the Subsidiary Company and received by the Assessee, were as part of the regular business transactions - it could not have been treated as 'loan' or 'advances', so as to make the disputed amounts as “deemed dividend”, as defined under Section 2(22)(e). - HC
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