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...
TDS u/s 194A - addition on account of Letter of Credit (LC) discount charges u/s 40(a)(ia) - the assessee has not made payment of interest to the bank or to the supplier and the amount credited to the suppliers’ account is towards reimbursement of expenses incurred by the suppliers - No TDS liability.
TDS u/s 194A - addition on account of Letter of Credit (LC) discount charges u/s 40(a)(ia) - the assessee has not made payment of interest to the bank or to the supplier and the amount credited to the suppliers’ account is towards reimbursement of expenses incurred by the suppliers - No TDS liability.
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