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...
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Disallowance of interest made or borrowed funds - Even before us also, general submissions have been made that the amounts have been utilized for commercial expediency purposes. It is for the assessee to prove that it is a part of commercial expediency and such interest free advance are given for the purpose of business and profession and if the assessee fails to satisfy then, the assessee cannot escape from such disallowance of interest expenditure - AT
Disallowance of interest made or borrowed funds - Even before us also, general submissions have been made that the amounts have been utilized for commercial expediency purposes. It is for the assessee to prove that it is a part of commercial expediency and such interest free advance are given for the purpose of business and profession and if the assessee fails to satisfy then, the assessee cannot escape from such disallowance of interest expenditure - AT
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