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 addition u/s 2(22)(e) - monies advanced to the assessee - no funds of the company is divested; there exists a current account which keeps fluctuating as per requirement of the funds that arise in the ordinary course of business and hence cannot be treated as deemed dividend under section 2(22)(e). - AT
Deemed dividend addition u/s 2(22)(e) - monies advanced to the assessee - no funds of the company is divested; there exists a current account which keeps fluctuating as per requirement of the funds that arise in the ordinary course of business and hence cannot be treated as deemed dividend under section 2(22)(e). - AT
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