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 194H - provision towards commission made - As similar provisions were made in earlier years as well as subsequent years by the assessee and the TDS was not deducted on the provisions. However, the Department has not made any additions with regard to the provisions made during the years in which returns of income were selected for scrutiny assessment. Therefore, the first substantial question of law on the analogy of the principles laid down by the Supreme Court in the aforesaid decision is answered against the revenue and in favour of the assessee. - HC
TDS u/s 194H - provision towards commission made - As similar provisions were made in earlier years as well as subsequent years by the assessee and the TDS was not deducted on the provisions. However, the Department has not made any additions with regard to the provisions made during the years in which returns of income were selected for scrutiny assessment. Therefore, the first substantial question of law on the analogy of the principles laid down by the Supreme Court in the aforesaid decision is answered against the revenue and in favour of the assessee. - HC
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TaxTMI 
TaxTMI 
of 4918 
