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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Nature of expenditure - software installed in their computer system - finding of facts recorded/affirmed by ITAT/CIT(A) after examination of the terms and conditions of the license that the assessee acquired only a right to use the software and that there was no enduring benefit acquired on account of the license promoted by them on payment of annual fee -revenue expenditure - no substantial question of law arises
Nature of expenditure - software installed in their computer system - finding of facts recorded/affirmed by ITAT/CIT(A) after examination of the terms and conditions of the license that the assessee acquired only a right to use the software and that there was no enduring benefit acquired on account of the license promoted by them on payment of annual fee -revenue expenditure - no substantial question of law arises
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