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...
Disallowance u/s 40(a)(i) - TDS u/s 195 OR 194A - interest paid to its Banker for import of certain goods from a supplier in USA - Section 194A shall not apply in case, such income is credited or paid to any banking company - For invoking Section 40(a)(i) the burden squarely lies on the AO to establish in the first instance that the relevant TDS provisions were applicable - no TDS liability u/s 195
Disallowance u/s 40(a)(i) - TDS u/s 195 OR 194A - interest paid to its Banker for import of certain goods from a supplier in USA - Section 194A shall not apply in case, such income is credited or paid to any banking company - For invoking Section 40(a)(i) the burden squarely lies on the AO to establish in the first instance that the relevant TDS provisions were applicable - no TDS liability u/s 195
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TaxTMI 
TaxTMI 
of 4918 
