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...
Levy of interest u/s 234B and 234C - Liability of advance tax - income from partnership firm in the hands of partner - As per the provisions of Sec. 10(2A) of the Act, the share of profit of the partnership firm is exempted in the hands of the partner. - both the provisions u/Sec 207 & Sec 208 are not inclusive and are independently applicable. The assessee case falls within the purview of provisions of section 207(2) of the Act which cannot be disputed. - Interest liability to be deleted - AT
Levy of interest u/s 234B and 234C - Liability of advance tax - income from partnership firm in the hands of partner - As per the provisions of Sec. 10(2A) of the Act, the share of profit of the partnership firm is exempted in the hands of the partner. - both the provisions u/Sec 207 & Sec 208 are not inclusive and are independently applicable. The assessee case falls within the purview of provisions of section 207(2) of the Act which cannot be disputed. - Interest liability to be deleted - AT
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