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...
Addition u/s.40(a)(ia) - assessee had paid interest to M/s. Tata Motors Finance Ltd. without deducting tax at source - when the assessee could not be held as an assessee-in-default u/s. 201(1) of the Act, therefore, we concur with the claim of the Ld. AR that as per the "2nd proviso" to Section 40(a)(ia) of the Act, the aforementioned amount could not have been disallowed in the hands of the assessee company. - AT
Addition u/s.40(a)(ia) - assessee had paid interest to M/s. Tata Motors Finance Ltd. without deducting tax at source - when the assessee could not be held as an assessee-in-default u/s. 201(1) of the Act, therefore, we concur with the claim of the Ld. AR that as per the "2nd proviso" to Section 40(a)(ia) of the Act, the aforementioned amount could not have been disallowed in the hands of the assessee company. - AT
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