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...
Disallowance of interest u/s 36(1)(iii) - Interest free loans granted - The Co-ordinate Bench of the Tribunal had previously ruled in favor of the assessee on a similar issue, highlighting that no disallowance can be made for amounts paid to parties in earlier years, which were standing as loans and advances. The Tribunal also emphasized that the concept of "commercial expediency" is crucial, and no disallowance can be made under Section 36(1)(iii) for amounts advanced for commercial reasons.
Disallowance of interest u/s 36(1)(iii) - Interest free loans granted - The Co-ordinate Bench of the Tribunal had previously ruled in favor of the assessee on a similar issue, highlighting that no disallowance can be made for amounts paid to parties in earlier years, which were standing as loans and advances. The Tribunal also emphasized that the concept of "commercial expediency" is crucial, and no disallowance can be made under Section 36(1)(iii) for amounts advanced for commercial reasons.
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TaxTMI 
TaxTMI 
of 4918 
