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...
Commission paid to a foreign director for marketing and sourcing export orders was held taxable under reverse charge because the director supplied services from outside India, the recipient was in India, and the place of supply under Section 13(2) was India, making it an import of services. Commission paid to foreign marketing agents was held not taxable because they were treated as intermediary services and, under Section 13(8), the place of supply was outside India, so the import of services condition failed. Charges paid to foreign clearing and forwarding agents for arrival, customs clearance and terminal handling services rendered abroad were held taxable under reverse charge as import of services.
Commission paid to a foreign director for marketing and sourcing export orders was held taxable under reverse charge because the director supplied services from outside India, the recipient was in India, and the place of supply under Section 13(2) was India, making it an import of services. Commission paid to foreign marketing agents was held not taxable because they were treated as intermediary services and, under Section 13(8), the place of supply was outside India, so the import of services condition failed. Charges paid to foreign clearing and forwarding agents for arrival, customs clearance and terminal handling services rendered abroad were held taxable under reverse charge as import of services.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
