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...
Deduction of Interest u/s 36(1) - Capital OR revenue - Assessee has also not claimed before us or before the Authorities below that the land in question was put to use in the Assessment Years in question - The words in the Proviso to Section 36(1) "whether capitalised or not" will override the provisions contained in Section 145A/accounting practice followed in the Books - not allowable
Deduction of Interest u/s 36(1) - Capital OR revenue - Assessee has also not claimed before us or before the Authorities below that the land in question was put to use in the Assessment Years in question - The words in the Proviso to Section 36(1) "whether capitalised or not" will override the provisions contained in Section 145A/accounting practice followed in the Books - not allowable
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