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...
TDS u/s 194C - determination of job work charges / miller cost - milling of paddy - As per AO milling costs paid by the appellant are discounted costs and need to be increased by the cost of by-products for the purpose of TDS - since we have held that the property in the by-product was not passed on by the assessee / Procurement Agencies as milling charges, hence, it is held that TDS provisions of section 194C are not attracted in this case. - AT
TDS u/s 194C - determination of job work charges / miller cost - milling of paddy - As per AO milling costs paid by the appellant are discounted costs and need to be increased by the cost of by-products for the purpose of TDS - since we have held that the property in the by-product was not passed on by the assessee / Procurement Agencies as milling charges, hence, it is held that TDS provisions of section 194C are not attracted in this case. - AT
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