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 14A r.w.r. 8D - the disallowances made u/s 14A of the Act r.w.r. 8D cannot be the subject matter of disallowances while determining the book profit u/s 115JB - Disallowance needs to be made in terms of the provisions of clause (f) to section 115JB of the Act while determining the book profit. - AT
Disallowance u/s 14A r.w.r. 8D - the disallowances made u/s 14A of the Act r.w.r. 8D cannot be the subject matter of disallowances while determining the book profit u/s 115JB - Disallowance needs to be made in terms of the provisions of clause (f) to section 115JB of the Act while determining the book profit. - AT
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