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...
Addition u/s 40A(3) - expenditure paid at various project sites in cash mode - unexplained expenditure - We invoke stricter interpretation of the impugned disallowance provision in Section 40A(3) that it is attracted only when an assessee incurs "any expenditure in respect of which a payment of aggregate of payments in a day" - CIT(A) rightly deleted the additins - AT
Addition u/s 40A(3) - expenditure paid at various project sites in cash mode - unexplained expenditure - We invoke stricter interpretation of the impugned disallowance provision in Section 40A(3) that it is attracted only when an assessee incurs "any expenditure in respect of which a payment of aggregate of payments in a day" - CIT(A) rightly deleted the additins - AT
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TaxTMI 
TaxTMI 
of 4918 
