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...
Non deduction of TDS - year-end provisions - disallowance u/s 40(a)(ia) - liability to make payment did not accrued on the appellant - Break-up of provision for expenses needs to be examined factually based on evidences in order to decide the applicability of TDS provisions. - Matter restored back - AT
Non deduction of TDS - year-end provisions - disallowance u/s 40(a)(ia) - liability to make payment did not accrued on the appellant - Break-up of provision for expenses needs to be examined factually based on evidences in order to decide the applicability of TDS provisions. - Matter restored back - AT
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