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...
An aborted IPO expenditure was treated as revenue expenditure allowable under section 37(1) because no asset came into existence and no enduring benefit was obtained. Receipts from foreign exchange differences and write-back of provisions were held to have a direct first-degree nexus with the export business of the 100% export-oriented unit, so section 10B deduction was allowed. Product development /expenses were not permitted to be spread as deferred revenue expenditure in the absence of statutory basis. Section 14A disallowance was confined to the exempt income earned. Loss on forward contracts entered into to hedge business exposure was held to be normal business loss, not speculation loss.
An aborted IPO expenditure was treated as revenue expenditure allowable under section 37(1) because no asset came into existence and no enduring benefit was obtained. Receipts from foreign exchange differences and write-back of provisions were held to have a direct first-degree nexus with the export business of the 100% export-oriented unit, so section 10B deduction was allowed. Product development /expenses were not permitted to be spread as deferred revenue expenditure in the absence of statutory basis. Section 14A disallowance was confined to the exempt income earned. Loss on forward contracts entered into to hedge business exposure was held to be normal business loss, not speculation loss.
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