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...
Interest on delayed statutory payments was held allowable as compensatory in nature, so disallowance of interest on delayed PF, ESI and service tax payments was not sustained. Cash payment disallowance under section 40A(3) failed because the assessee produced books, labour records and attendance material, and no specific payment to a single person in a day above the statutory threshold was identified. Addition under section 68 was deleted because the receipts were found to be business advances from customers against supply of goods, not unexplained cash credits. The Revenue's challenge was dismissed and the appellate order was upheld.
Interest on delayed statutory payments was held allowable as compensatory in nature, so disallowance of interest on delayed PF, ESI and service tax payments was not sustained. Cash payment disallowance under section 40A(3) failed because the assessee produced books, labour records and attendance material, and no specific payment to a single person in a day above the statutory threshold was identified. Addition under section 68 was deleted because the receipts were found to be business advances from customers against supply of goods, not unexplained cash credits. The Revenue's challenge was dismissed and the appellate order was upheld.
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