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...
Long Term Capital gain computation - interest capitalized to cost of asset - It is not in dispute that the property was acquired by a borrowed capital initially borrowed from the relatives of the Directors. Thereafter, the loan taken from such persons was repaid out of the loan received from ICICI bank. - it cannot be construed that there is no nexus between the acquisition of the property and the utilization of the capital so borrowed. - AO hereby directed to allow capitalization of interest - AT
Long Term Capital gain computation - interest capitalized to cost of asset - It is not in dispute that the property was acquired by a borrowed capital initially borrowed from the relatives of the Directors. Thereafter, the loan taken from such persons was repaid out of the loan received from ICICI bank. - it cannot be construed that there is no nexus between the acquisition of the property and the utilization of the capital so borrowed. - AO hereby directed to allow capitalization of interest - AT
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