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...
Ad hoc disallowance of employee-benefit and business expenditure lacks basis where no expenditure is identified as non-genuine, excessive or non-business, and the books are not rejected; missing vouchers justify item-specific verification, not a blanket estimate. Cash deposits attributed to recorded multi-outlet sales cannot be reclassified as unexplained cash credits without evidence that they comprised Specified Bank Notes or that the underlying books, sales or stock records were defective; taxing recorded receipts again produces double taxation. Loan credits require verification of lender records, immediate source, and repayment or adjustment entries; confirmations, PAN details and banking entries require assessment alongside those records, while unsecured or interest-free terms alone do not justify an addition.
Ad hoc disallowance of employee-benefit and business expenditure lacks basis where no expenditure is identified as non-genuine, excessive or non-business, and the books are not rejected; missing vouchers justify item-specific verification, not a blanket estimate. Cash deposits attributed to recorded multi-outlet sales cannot be reclassified as unexplained cash credits without evidence that they comprised Specified Bank Notes or that the underlying books, sales or stock records were defective; taxing recorded receipts again produces double taxation. Loan credits require verification of lender records, immediate source, and repayment or adjustment entries; confirmations, PAN details and banking entries require assessment alongside those records, while unsecured or interest-free terms alone do not justify an addition.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4921 
