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...
Commission paid to director is allowable business expenditure u/s 36(1)(ii) as assessee provided substantial evidence demonstrating services rendered and resultant benefits; AO failed to prove payment was made to avoid DDT. Weighted deduction claim u/s 35(2AB) allowed in full; AO cannot solely rely on DSIR report without considering assessee's books of accounts and chartered accountant's certification. Principles of natural justice require providing reasons for reducing claim and opportunity to respond.
Commission paid to director is allowable business expenditure u/s 36(1)(ii) as assessee provided substantial evidence demonstrating services rendered and resultant benefits; AO failed to prove payment was made to avoid DDT. Weighted deduction claim u/s 35(2AB) allowed in full; AO cannot solely rely on DSIR report without considering assessee's books of accounts and chartered accountant's certification. Principles of natural justice require providing reasons for reducing claim and opportunity to respond.
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