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...
Claim of deduction of Provisions made - Basis of creating the provision - uncertain liability or not - The above facts would substantiate that the provision has been made for material cost and/or compensation for cancellation/suspension of contracts which is incurred under contracts with its vendors entered pursuant to pre-existing commitments against supply contracts with customers, the latter having been subsequently cancelled/suspended. Hence, we hold that the provision is an allowable deduction. - AT
Claim of deduction of Provisions made - Basis of creating the provision - uncertain liability or not - The above facts would substantiate that the provision has been made for material cost and/or compensation for cancellation/suspension of contracts which is incurred under contracts with its vendors entered pursuant to pre-existing commitments against supply contracts with customers, the latter having been subsequently cancelled/suspended. Hence, we hold that the provision is an allowable deduction. - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
