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...
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Disallowance of Sales Promotion, Advertisement and Publicity Expenses - when assessee is able to provide the business nexus of incurrence of expenditure with supporting documents, it cannot be simply denied/rejected merely on the ground of propriety, which action would lead to, travelling beyond the brief and stepping into the shoes of the assessee by the revenue - no disallowance
Disallowance of Sales Promotion, Advertisement and Publicity Expenses - when assessee is able to provide the business nexus of incurrence of expenditure with supporting documents, it cannot be simply denied/rejected merely on the ground of propriety, which action would lead to, travelling beyond the brief and stepping into the shoes of the assessee by the revenue - no disallowance
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