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...
Retrospectively amended Section 115JA was applied to treat amounts set aside for bad and doubtful debts as a provision for diminution in the value of an asset, so the addition in book profit computation was upheld and the assessee's challenge failed. By contrast, the audit report requirement for a deduction claim under Section 80IA(7) was treated as directory for the relevant period, so failure to file it before assessment did not defeat the claim when the report was produced before the appellate authority. The appeal was therefore partly allowed, with the Revenue succeeding on book profit treatment and the assessee succeeding on the audit-report issue.
Retrospectively amended Section 115JA was applied to treat amounts set aside for bad and doubtful debts as a provision for diminution in the value of an asset, so the addition in book profit computation was upheld and the assessee's challenge failed. By contrast, the audit report requirement for a deduction claim under Section 80IA(7) was treated as directory for the relevant period, so failure to file it before assessment did not defeat the claim when the report was produced before the appellate authority. The appeal was therefore partly allowed, with the Revenue succeeding on book profit treatment and the assessee succeeding on the audit-report issue.
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TaxTMI 
TaxTMI 
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