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...
Deemed dividend u/s 2(22)(e) - The AO held that loans received by the assessee from the Company constituted deemed dividends. However, the Appellate Tribunal found that there were no withdrawals of loans during the relevant year, leading to the conclusion that the additions proposed by the Assessing Officer were unwarranted. Consequently, the Tribunal ruled in favor of the assessee and deleted the proposed additions.
Deemed dividend u/s 2(22)(e) - The AO held that loans received by the assessee from the Company constituted deemed dividends. However, the Appellate Tribunal found that there were no withdrawals of loans during the relevant year, leading to the conclusion that the additions proposed by the Assessing Officer were unwarranted. Consequently, the Tribunal ruled in favor of the assessee and deleted the proposed additions.
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