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...
Addition made u/s. 40A(2)(b) for excess payment made to related party - The tribunal noted that the assessee provided substantial evidence of higher purchase rates from unrelated parties and that both entities were in a loss scenario, negating any tax advantage motive. Thus, the addition was deleted.
Addition made u/s. 40A(2)(b) for excess payment made to related party - The tribunal noted that the assessee provided substantial evidence of higher purchase rates from unrelated parties and that both entities were in a loss scenario, negating any tax advantage motive. Thus, the addition was deleted.
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