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 195 - reimbursement of travelling expenses paid to foreign parties - a payment in the nature of a mere reimbursement of actual expenses would not be covered by the obligations cast under s. 195 of the Act in the absence of any chargeable income annexed to such payment and consequently Section 40(a)(i) would not be attracted - AT
TDS u/s 195 - reimbursement of travelling expenses paid to foreign parties - a payment in the nature of a mere reimbursement of actual expenses would not be covered by the obligations cast under s. 195 of the Act in the absence of any chargeable income annexed to such payment and consequently Section 40(a)(i) would not be attracted - AT
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