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...
Characterization of receipt - Compensation receipt on termination of contract - Addition under Section 28(ii)(e) - The Tribunal differentiates between termination and non-renewal of a contract and argues that the compensation received due to non-renewal should not be treated as termination under Section 28(ii)(e) or Section 56(2)(xi). - Reference is made to section 2(zh) of the Industrial Relations Code, 2020, to support the argument that non-renewal of a contract is distinct from retrenchment. - AO directed to delete the additions.
Characterization of receipt - Compensation receipt on termination of contract - Addition under Section 28(ii)(e) - The Tribunal differentiates between termination and non-renewal of a contract and argues that the compensation received due to non-renewal should not be treated as termination under Section 28(ii)(e) or Section 56(2)(xi). - Reference is made to section 2(zh) of the Industrial Relations Code, 2020, to support the argument that non-renewal of a contract is distinct from retrenchment. - AO directed to delete the additions.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
