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...
Income from other sources - Deduction of interest expenditure - direction of the CIT – A in restricting the deduction to the extent of income earned of term deposit - The Appellate Tribunal noted that the appellant had earned bank interest of Rs. 41 lakhs. - Following previous decisions of the Coordinate Bench, the Tribunal directed the AO to allow the deduction of interest expenditure of Rs. 3.27 crores, as claimed by the appellant. - The Tribunal found that the interest expenditure was indeed incurred for the purpose of earning interest income, based on precedents and the nature of the transactions.
Income from other sources - Deduction of interest expenditure - direction of the CIT – A in restricting the deduction to the extent of income earned of term deposit - The Appellate Tribunal noted that the appellant had earned bank interest of Rs. 41 lakhs. - Following previous decisions of the Coordinate Bench, the Tribunal directed the AO to allow the deduction of interest expenditure of Rs. 3.27 crores, as claimed by the appellant. - The Tribunal found that the interest expenditure was indeed incurred for the purpose of earning interest income, based on precedents and the nature of the transactions.
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