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...
The ITAT Surat held that interest and remuneration received by the assessee as a partner of a firm are taxable u/s 28(v) of the Act. The assessee can claim deductions u/s 30 to 43D. Expenditure claimed u/s 37 must meet specific criteria: not covered by u/s 30-36, not capital, not personal, for business/profession, incurred in the year, not illegal. The car-related expenses claimed lacked evidence of business use. 50% allowed for business use, reducing disallowed amount to Rs. 2,71,322. The assessee's appeal partly allowed.
The ITAT Surat held that interest and remuneration received by the assessee as a partner of a firm are taxable u/s 28(v) of the Act. The assessee can claim deductions u/s 30 to 43D. Expenditure claimed u/s 37 must meet specific criteria: not covered by u/s 30-36, not capital, not personal, for business/profession, incurred in the year, not illegal. The car-related expenses claimed lacked evidence of business use. 50% allowed for business use, reducing disallowed amount to Rs. 2,71,322. The assessee's appeal partly allowed.
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