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 u/s 10AA - once separate books of account have been maintained for each of the undertakings, there is no basis for the AO to allege that any of the expenses of non-SEZ units pertained to revenue of eligible units. Once such expenses has also not been claimed, the same is of no consequences. - AT
Deduction u/s 10AA - once separate books of account have been maintained for each of the undertakings, there is no basis for the AO to allege that any of the expenses of non-SEZ units pertained to revenue of eligible units. Once such expenses has also not been claimed, the same is of no consequences. - AT
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