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...
Unsecured loans alleged to be accommodation entries require evaluation of lender identity, creditworthiness and transaction genuineness. Confirmations, bank statements, ledger accounts, receipt through banking channels, and repayment with interest support those requirements; generic third-party search information or allegations of entry providers do not, without contrary material, displace such evidence. Interest expenditure connected with a supported loan requires evidence of actual incurrence or payment, rather than presumption or estimation based merely on an alleged consequential liability.
Unsecured loans alleged to be accommodation entries require evaluation of lender identity, creditworthiness and transaction genuineness. Confirmations, bank statements, ledger accounts, receipt through banking channels, and repayment with interest support those requirements; generic third-party search information or allegations of entry providers do not, without contrary material, displace such evidence. Interest expenditure connected with a supported loan requires evidence of actual incurrence or payment, rather than presumption or estimation based merely on an alleged consequential liability.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
