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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Disallowance of interest u/s. 36(1)(iii) - partners of the assessee firm had over withdrawn an amount as in excess of what was brought by them in the firm - the assessee did not have any interest free advances - now when the partners of the assessee firm had clearly over withdrawn an amount in excess of what was brought by them in the firm, therefore, the lower authorities had rightly concluded that the correlating interest expenditure pertaining to the amount so overdrawn was liable to be disallowed u/s.36(1)(iii) - AT
Disallowance of interest u/s. 36(1)(iii) - partners of the assessee firm had over withdrawn an amount as in excess of what was brought by them in the firm - the assessee did not have any interest free advances - now when the partners of the assessee firm had clearly over withdrawn an amount in excess of what was brought by them in the firm, therefore, the lower authorities had rightly concluded that the correlating interest expenditure pertaining to the amount so overdrawn was liable to be disallowed u/s.36(1)(iii) - AT
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