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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TDS u/s 194IA - payment for land advance - non-deduction of TDS in violation of Section 40(a)(ia) - the provisions of Section 40(a)(ia) are applicable only to the expenditure claimed while computing income under the head “profit and gains of business or profession” of the Income Tax Act, 1961. In this case, this amount has not been claimed as expenditure being the amount paid as advance for acquisition of a capital asset. - No additions could be made - AT
TDS u/s 194IA - payment for land advance - non-deduction of TDS in violation of Section 40(a)(ia) - the provisions of Section 40(a)(ia) are applicable only to the expenditure claimed while computing income under the head “profit and gains of business or profession” of the Income Tax Act, 1961. In this case, this amount has not been claimed as expenditure being the amount paid as advance for acquisition of a capital asset. - No additions could be made - AT
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