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...
Expenditure incurred in respect of ESOP (Employees Stock Option Programme) - the employees have been given shares of the holding company at a discounted price and the assessee has borne the discount amount on behalf of its employees. - Hence, in effect, it is a staff welfare programme of the assessee and hence the same is allowable as deduction u/s 37(1) - AT
Expenditure incurred in respect of ESOP (Employees Stock Option Programme) - the employees have been given shares of the holding company at a discounted price and the assessee has borne the discount amount on behalf of its employees. - Hence, in effect, it is a staff welfare programme of the assessee and hence the same is allowable as deduction u/s 37(1) - AT
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