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...
Research and Development expenses (R&D Expenses) - Allowability of expenses u/s 35(2) - The expenses are not covered u/s 35(2) - The assessee has not claimed the same u/s 35(2) but the expenses are allowable u/s 35(1) @ 100%. Since, the ratio of incurring of expenses per se is not in dispute, we hold that the assessee is eligible to claim expenses u/s 35(1). The approval of the DSIR is not required for claim u/s 35(1)(i). - AT
Research and Development expenses (R&D Expenses) - Allowability of expenses u/s 35(2) - The expenses are not covered u/s 35(2) - The assessee has not claimed the same u/s 35(2) but the expenses are allowable u/s 35(1) @ 100%. Since, the ratio of incurring of expenses per se is not in dispute, we hold that the assessee is eligible to claim expenses u/s 35(1). The approval of the DSIR is not required for claim u/s 35(1)(i). - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
