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 the claim for Bad Debts written off - Disallowance of settlement expenditure - In the case of bad debts, the Appellate Tribunal (ITAT) partially allowed the appeal, permitting the write-off related to business activities while rejecting the claim related to capital expenditures. Regarding the settlement expenditure, the Tribunal allowed the appeal, recognizing the guarantee given by the assessee as essential for business operations and the payment made to settle the liability as a necessary expense for business continuity.
Disallowance of the claim for Bad Debts written off - Disallowance of settlement expenditure - In the case of bad debts, the Appellate Tribunal (ITAT) partially allowed the appeal, permitting the write-off related to business activities while rejecting the claim related to capital expenditures. Regarding the settlement expenditure, the Tribunal allowed the appeal, recognizing the guarantee given by the assessee as essential for business operations and the payment made to settle the liability as a necessary expense for business continuity.
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