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...
Deduction under section 80IA concerned the allowability and apportionment of common salary expenses between a power generation unit and a share trading business. The tribunal accepted the salary claimed as debited to profit and loss but held that the allocation between the two businesses should be made by reference to their respective turnover, not a fixed 50:50 split; it set aside the AO's allocation and directed recomputation of the 80IA deduction by apportioning salary in the ratio of turnover. Grounds raised by the assessee were partly allowed.
Deduction under section 80IA concerned the allowability and apportionment of common salary expenses between a power generation unit and a share trading business. The tribunal accepted the salary claimed as debited to profit and loss but held that the allocation between the two businesses should be made by reference to their respective turnover, not a fixed 50:50 split; it set aside the AO's allocation and directed recomputation of the 80IA deduction by apportioning salary in the ratio of turnover. Grounds raised by the assessee were partly allowed.
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