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...
The note addresses tax deductibility of business expenses where liability crystallises in the relevant previous year but payment occurs later. It states the principle that expenses incurred wholly and exclusively for business are deductible in the year the liability crystallised; subsequent payment does not defeat deduction if records show liability and tax deducted at source. Applying this to compression and blasting expenses, the author concludes these expenses were business-related, liability had crystallised in the relevant previous year, and therefore deduction for the assessment year was justified.
The note addresses tax deductibility of business expenses where liability crystallises in the relevant previous year but payment occurs later. It states the principle that expenses incurred wholly and exclusively for business are deductible in the year the liability crystallised; subsequent payment does not defeat deduction if records show liability and tax deducted at source. Applying this to compression and blasting expenses, the author concludes these expenses were business-related, liability had crystallised in the relevant previous year, and therefore deduction for the assessment year was justified.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4921 
