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...
Section 43D and Rule 6EB form a comprehensive code for deduction on account of non-performing assets (NPAs), distinct from NHB guidelines classifying NPAs. The court held that the tax provisions allow discretion to follow or not follow NHB guidelines when revised. The purpose of NPA classification by NHB differs from non-recognition of income under tax laws. The real income principle is inapplicable to Section 43D deductions, which must satisfy statutory conditions, separate from NHB's prudential norms. The Supreme Court upheld the High Court's decision, dismissing the petition and vacating interim relief granted earlier.
Section 43D and Rule 6EB form a comprehensive code for deduction on account of non-performing assets (NPAs), distinct from NHB guidelines classifying NPAs. The court held that the tax provisions allow discretion to follow or not follow NHB guidelines when revised. The purpose of NPA classification by NHB differs from non-recognition of income under tax laws. The real income principle is inapplicable to Section 43D deductions, which must satisfy statutory conditions, separate from NHB's prudential norms. The Supreme Court upheld the High Court's decision, dismissing the petition and vacating interim relief granted earlier.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
