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 under section 234C - It is pertinent to note that provisions of section 234C of the Act refers to the term “returned income” in comparison to the provisions of section 234B of the Act which refers to the term “assessed income” for imposing interest. The Assessing Officer is directed to re–compute the interest under section 234C of the Act on the basis of “returned income” in case there is default / short fall in payment of advance tax as compared to tax due on returned income. - AT
Levy of interest under section 234C - It is pertinent to note that provisions of section 234C of the Act refers to the term “returned income” in comparison to the provisions of section 234B of the Act which refers to the term “assessed income” for imposing interest. The Assessing Officer is directed to re–compute the interest under section 234C of the Act on the basis of “returned income” in case there is default / short fall in payment of advance tax as compared to tax due on returned income. - AT
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