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...
Year-end provisions for audit fees and contractor payments remain deductible where consistently accrued, discharged subsequently, and excess provisions are reversed and offered to tax. Unclaimed interest or capital expenditure recorded in the balance sheet cannot be added merely because it appears as an accrued liability. Section 251 permits remand or setting aside only for ex parte assessments under section 144, making remand for fresh verification impermissible for assessments under section 143(3). No disallowance arises for payments not subject to tax deduction at source or for expenditure relating to exempt income where no exempt income is earned. Income already offered to tax cannot be taxed again; actuarially valued leave-encashment liabilities are deductible; and under-reporting penalty requires valid initiation with recorded satisfaction.
Year-end provisions for audit fees and contractor payments remain deductible where consistently accrued, discharged subsequently, and excess provisions are reversed and offered to tax. Unclaimed interest or capital expenditure recorded in the balance sheet cannot be added merely because it appears as an accrued liability. Section 251 permits remand or setting aside only for ex parte assessments under section 144, making remand for fresh verification impermissible for assessments under section 143(3). No disallowance arises for payments not subject to tax deduction at source or for expenditure relating to exempt income where no exempt income is earned. Income already offered to tax cannot be taxed again; actuarially valued leave-encashment liabilities are deductible; and under-reporting penalty requires valid initiation with recorded satisfaction.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
