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...
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Regarding TDS u/s 194IA on share of each partner/owner of a joint property, where assessee purchased land along with his brother, it was held that considering section 194-IA and case precedent, since assessee was responsible for paying consideration only for his share and paid accordingly, there was no requirement to deduct tax at source. Hence, demand u/s 201(1) and 201(IA) was set aside, and assessee's appeal was allowed.
Regarding TDS u/s 194IA on share of each partner/owner of a joint property, where assessee purchased land along with his brother, it was held that considering section 194-IA and case precedent, since assessee was responsible for paying consideration only for his share and paid accordingly, there was no requirement to deduct tax at source. Hence, demand u/s 201(1) and 201(IA) was set aside, and assessee's appeal was allowed.
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