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...
Related-party payment under section 40A(2)(a) cannot be disallowed unless excessiveness is tested against a truly comparable service; email marketing charges were deleted because the Assessing Officer compared dissimilar services and the record did not support the conclusion of excess payment. Depreciation and car-loan interest were allowed where the vehicles were kept ready for use, since actual use is not the sole test for business assets maintained in a state of readiness. Recruitment, placement and staff welfare es were disallowed because the assessee had admitted during assessment that no employees existed during the year and the amount was offered for disallowance.
Related-party payment under section 40A(2)(a) cannot be disallowed unless excessiveness is tested against a truly comparable service; email marketing charges were deleted because the Assessing Officer compared dissimilar services and the record did not support the conclusion of excess payment. Depreciation and car-loan interest were allowed where the vehicles were kept ready for use, since actual use is not the sole test for business assets maintained in a state of readiness. Recruitment, placement and staff welfare es were disallowed because the assessee had admitted during assessment that no employees existed during the year and the amount was offered for disallowance.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
