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...
Work Contract Tax actually paid during the relevant previous year is deductible for an assessee consistently following the cash system of accounting, even where the statutory liability relates to earlier financial years. Once the books and accounting method are accepted, mercantile principles cannot be selectively applied to deny the deduction without material showing a mercantile method, manipulation, or accounting defects warranting intervention. Interest paid solely for delayed payment of Work Contract Tax is compensatory rather than penal in nature. As it compensates the State for delayed use of funds and relates to statutory business liability, the interest is allowable as a business deduction.
Work Contract Tax actually paid during the relevant previous year is deductible for an assessee consistently following the cash system of accounting, even where the statutory liability relates to earlier financial years. Once the books and accounting method are accepted, mercantile principles cannot be selectively applied to deny the deduction without material showing a mercantile method, manipulation, or accounting defects warranting intervention. Interest paid solely for delayed payment of Work Contract Tax is compensatory rather than penal in nature. As it compensates the State for delayed use of funds and relates to statutory business liability, the interest is allowable as a business deduction.
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