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...
Deemed dividend u/s 2(22)(e) - amount received by the assessee from his father - family settlement - transfer of money from father to son is nothing unusual - The observation of AO that the agreement is artificially created for the purpose of withdrawing money by the assessee from the accumulated profits of MEL is not maintainable.
Deemed dividend u/s 2(22)(e) - amount received by the assessee from his father - family settlement - transfer of money from father to son is nothing unusual - The observation of AO that the agreement is artificially created for the purpose of withdrawing money by the assessee from the accumulated profits of MEL is not maintainable.
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