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...
Allowable as business expenses - Small contributions to local people and institution on request of employees and business associates - Section 37 of the Act contemplates that any expenditure not being expenditure of the nature described in sections 32 to 36 and not being in the nature of capital expenditure or personal expenses of the assessee laid out or expended wholly and exclusively for the purpose of the business or profession shall be allowed in computing the income chargeable under the Head “Profits & Gains of Business or Profession”. AO failed to appreciate the nature of business of the assessee and the surrounding social environment where it has been carrying out its business. - AT
Allowable as business expenses - Small contributions to local people and institution on request of employees and business associates - Section 37 of the Act contemplates that any expenditure not being expenditure of the nature described in sections 32 to 36 and not being in the nature of capital expenditure or personal expenses of the assessee laid out or expended wholly and exclusively for the purpose of the business or profession shall be allowed in computing the income chargeable under the Head “Profits & Gains of Business or Profession”. AO failed to appreciate the nature of business of the assessee and the surrounding social environment where it has been carrying out its business. - AT
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