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...
Assessee's case remanded to Assessing Officer to consider taxability of loan waiver under One Time Settlement Scheme with bank. If loan was for trading purpose, waiver would amount to cessation of liability, taxable u/s 41(1). Authorities below did not consider applicability of Section 41(1) despite assessee's submission. Facts relevant to loan waiver need to be brought on record to determine under which section benefit from One Time Settlement is taxable. Revenue's appeal allowed for statistical purpose.
Assessee's case remanded to Assessing Officer to consider taxability of loan waiver under One Time Settlement Scheme with bank. If loan was for trading purpose, waiver would amount to cessation of liability, taxable u/s 41(1). Authorities below did not consider applicability of Section 41(1) despite assessee's submission. Facts relevant to loan waiver need to be brought on record to determine under which section benefit from One Time Settlement is taxable. Revenue's appeal allowed for statistical purpose.
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