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...
Deduction claimed u/s 57 against income returned u/s 56 - manner of apportioning assessee's expenses to earning income u/s 56 disputed - Revenue authorities rejecting assessee's apportionment and allocating expenses on different basis challenged - Issue remanded to Assessing Officer to verify if formula adopted by assessee for apportioning interest expenses to interest income u/s 56 is consistent with previous assessment year accepted by Assessing Officer - If consistent, no addition to assessee's income - Assessing Officer directed to apportion expenses u/s 57 in line with previous year's assessment - Appeal allowed for statistical purposes.
Deduction claimed u/s 57 against income returned u/s 56 - manner of apportioning assessee's expenses to earning income u/s 56 disputed - Revenue authorities rejecting assessee's apportionment and allocating expenses on different basis challenged - Issue remanded to Assessing Officer to verify if formula adopted by assessee for apportioning interest expenses to interest income u/s 56 is consistent with previous assessment year accepted by Assessing Officer - If consistent, no addition to assessee's income - Assessing Officer directed to apportion expenses u/s 57 in line with previous year's assessment - Appeal allowed for statistical purposes.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4921 
