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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Transfer pricing adjustment on quasi-equity transaction like non-convertible cumulative redeemable preference shares necessitates benchmarking cost with international LIBOR rates considering risk factors. Lease accounting principles differ for operating and finance leases; depreciation allowable on assets under finance lease. Employees' share option scheme expenses deductible subject to fulfillment of conditions. Disallowance u/s 14A restricted to investments yielding exempt income. Section 14A disallowance excluded from book profit computation u/s 115JB. Cash deposits during demonetization by authorized forex dealer requires substantiation. Depreciation allowable on property despite temporary letting if used for business. Indexation benefit available while computing book profit u/s 115JB.
Transfer pricing adjustment on quasi-equity transaction like non-convertible cumulative redeemable preference shares necessitates benchmarking cost with international LIBOR rates considering risk factors. Lease accounting principles differ for operating and finance leases; depreciation allowable on assets under finance lease. Employees' share option scheme expenses deductible subject to fulfillment of conditions. Disallowance u/s 14A restricted to investments yielding exempt income. Section 14A disallowance excluded from book profit computation u/s 115JB. Cash deposits during demonetization by authorized forex dealer requires substantiation. Depreciation allowable on property despite temporary letting if used for business. Indexation benefit available while computing book profit u/s 115JB.
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