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...
Disallowance of the interest expenditure on the loan taken by the assessee - The transactions are driven by business considerations and are part of the commercial expediency, we are of the considered opinion that the disallowance of interest expense on loan taken for purposes of business and against which interest income has been earned and offered to tax is unwarranted and the same qualifies to be allowed u/s.36(1)(iii)/S.37(l). - AT
Disallowance of the interest expenditure on the loan taken by the assessee - The transactions are driven by business considerations and are part of the commercial expediency, we are of the considered opinion that the disallowance of interest expense on loan taken for purposes of business and against which interest income has been earned and offered to tax is unwarranted and the same qualifies to be allowed u/s.36(1)(iii)/S.37(l). - AT
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