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...
Allowability of working partner remuneration and tax treatment of commission on cash basis are examined. The article explains that where a partnership deed expressly adopts the statutory definition of book profit and authorises remuneration, an inadvertent numeric discrepancy in the deed does not negate authorisation; remuneration quantification is for the firm and payments within statutory computation limits are allowable, especially where the partner declared the amount separately. Separately, a consistent accounting policy of recognising commission on a cash basis, supported by disclosures and documentary evidence that amounts shown in Form 26AS were not received until a later year, justifies deferring taxation and claiming TDS credit when received.
Allowability of working partner remuneration and tax treatment of commission on cash basis are examined. The article explains that where a partnership deed expressly adopts the statutory definition of book profit and authorises remuneration, an inadvertent numeric discrepancy in the deed does not negate authorisation; remuneration quantification is for the firm and payments within statutory computation limits are allowable, especially where the partner declared the amount separately. Separately, a consistent accounting policy of recognising commission on a cash basis, supported by disclosures and documentary evidence that amounts shown in Form 26AS were not received until a later year, justifies deferring taxation and claiming TDS credit when received.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
