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...
Disallowance made u/s.14A of the Act while computing book profit u/s.115JB - actual expenses debited to profit and loss account which are incurred for the purpose of earning exempt income need to be disallowed under Clause (f) of Explanation 1 to Section 115JB(2) of the Act. As stated supra, we find that assessee had already made disallowance voluntarily in the return of income which alone need to be considered for the purpose of computation of book profits u/s 115JB of the Act. Hence, no further disallowance need to be made thereon. - AT
Disallowance made u/s.14A of the Act while computing book profit u/s.115JB - actual expenses debited to profit and loss account which are incurred for the purpose of earning exempt income need to be disallowed under Clause (f) of Explanation 1 to Section 115JB(2) of the Act. As stated supra, we find that assessee had already made disallowance voluntarily in the return of income which alone need to be considered for the purpose of computation of book profits u/s 115JB of the Act. Hence, no further disallowance need to be made thereon. - AT
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