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...
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Additions u/s 28(iv) - Business perquisite - ECB loan as received from the holding company by the assessee in convertible foreign exchange for the purpose of acquiring assets in the earlier years. The said loan has been waived and credited to the capital reserve - Therefore, there is no benefit or perquisite other than in the shape of money to invoke the provisions of section 28 (iv) - AT
Additions u/s 28(iv) - Business perquisite - ECB loan as received from the holding company by the assessee in convertible foreign exchange for the purpose of acquiring assets in the earlier years. The said loan has been waived and credited to the capital reserve - Therefore, there is no benefit or perquisite other than in the shape of money to invoke the provisions of section 28 (iv) - AT
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