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...
Disallowance u/s 40A(2)(b) for excessive payments to related concerns was deleted based on CBDT Circular 6-P and case laws of Delhi HC in Sigma Research and Bombay HC in Indo Saudi Services, holding that disallowance is unsustainable when payer and payee are taxed at same rate. ITAT ruled in favour of the assessee.
Disallowance u/s 40A(2)(b) for excessive payments to related concerns was deleted based on CBDT Circular 6-P and case laws of Delhi HC in Sigma Research and Bombay HC in Indo Saudi Services, holding that disallowance is unsustainable when payer and payee are taxed at same rate. ITAT ruled in favour of the assessee.
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TaxTMI 
TaxTMI 
of 4921 
