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...
Interest on capital paid to the partner - payment of interest by the two partnership firms towards use of partners’ capital - Expenditure incurred on account of commercial expediency or not? - Since the amount has been taxed in the hands of partners u/s 28(v) of the Act same to be allowed in the hands of the assessee u/s 40(b) of the Act, otherwise it amounts to double taxation - AO directed to allow the deduction to the extent of limit prescribed in section 40(b) - AT
Interest on capital paid to the partner - payment of interest by the two partnership firms towards use of partners’ capital - Expenditure incurred on account of commercial expediency or not? - Since the amount has been taxed in the hands of partners u/s 28(v) of the Act same to be allowed in the hands of the assessee u/s 40(b) of the Act, otherwise it amounts to double taxation - AO directed to allow the deduction to the extent of limit prescribed in section 40(b) - AT
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