Jurisdictional sanction requirements bar reassessment when approval comes from an authority lacking statutory competence under the applicable framewor...
Recorded sales receipts cannot be reassessed as unexplained cash credits, eliminating the basis for consequential alleged commission expenditure addit...
Sufficient cause for delayed income-tax appeals requires bona fide diligence; unsubstantiated counsel illness and assessee inaction defeat condonation...
TNMM Segmentation Limits Transfer-Pricing Adjustments to Associated-Enterprise Transactions and Requires Turnover-Based Comparable Selection for IT Se...
Addition u/s 40A(2) - assessee has paid interest to certain related parties and treated interest rate @ 15% reasonable and disallowed excess rate paid to related parties u/s.40A(2) - different banks/NBFC’s are having different interest rates for business loan if any one require loan in emergency from local money lenders then in that case one has to pay interest rate between 48% to 60%. So in our considered opinion in this case difference of interest which was received by the assessee or paid by it is just 1.25% per annum so same cannot be termed as unreasonable. - AT
Addition u/s 40A(2) - assessee has paid interest to certain related parties and treated interest rate @ 15% reasonable and disallowed excess rate paid to related parties u/s.40A(2) - different banks/NBFC’s are having different interest rates for business loan if any one require loan in emergency from local money lenders then in that case one has to pay interest rate between 48% to 60%. So in our considered opinion in this case difference of interest which was received by the assessee or paid by it is just 1.25% per annum so same cannot be termed as unreasonable. - AT
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TaxTMI 
TaxTMI 
