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...
Addition on account of Sales Commission - Non-deduction of TDS u/s 194H - Payment of commission of employees as part of sale or otherwise - Merely, the claim made by the assessee that the business of the Appellant is sales/purchase of liquor and all these employees are directly or indirectly related to sales of the company is not sufficient to hold that the findings of the authorities below are not tenable. - AT
Addition on account of Sales Commission - Non-deduction of TDS u/s 194H - Payment of commission of employees as part of sale or otherwise - Merely, the claim made by the assessee that the business of the Appellant is sales/purchase of liquor and all these employees are directly or indirectly related to sales of the company is not sufficient to hold that the findings of the authorities below are not tenable. - AT
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