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...
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Deduction of expenditure representing TDS amount as deducted but not deposited following the Cash Basis of accounting - The amount of tax deducted at source is always considered as the sum paid by the assessee on behalf of the recipient of the income. - Therefore, it cannot be said that the above sum has not been paid by the assessee even while following the cash system of accounting. - deduction of expenditure allowed - AT
Deduction of expenditure representing TDS amount as deducted but not deposited following the Cash Basis of accounting - The amount of tax deducted at source is always considered as the sum paid by the assessee on behalf of the recipient of the income. - Therefore, it cannot be said that the above sum has not been paid by the assessee even while following the cash system of accounting. - deduction of expenditure allowed - AT
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