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...
Deemed dividend u/s 2(22)(e) - accumulated profits would mean profit in the commercial sense and not assessable taxable profits - share premium account would not partake the nature of commercial profits and therefore, by no stretch of imagination, this can be called accumulated profits - AT
Deemed dividend u/s 2(22)(e) - accumulated profits would mean profit in the commercial sense and not assessable taxable profits - share premium account would not partake the nature of commercial profits and therefore, by no stretch of imagination, this can be called accumulated profits - AT
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