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...
TDS u/s 194C / 194H - Disallowances u/s 40(a)(ia) - the rebate/discount given by the assessee to the dealers will not coming either within the purview of section 194C or section 194H therefore, would not require deduction of tax at source. - Even AO was not sure, whether it is a payment for carrying out any work or is in the nature of commission / brokerage for any service rendered by another party in the course of buying and selling a product. - AT
TDS u/s 194C / 194H - Disallowances u/s 40(a)(ia) - the rebate/discount given by the assessee to the dealers will not coming either within the purview of section 194C or section 194H therefore, would not require deduction of tax at source. - Even AO was not sure, whether it is a payment for carrying out any work or is in the nature of commission / brokerage for any service rendered by another party in the course of buying and selling a product. - AT
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