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...
Receipts from SaaS-based product analytics services rendered to Indian customers were held not taxable as royalty or as fees for technical services/included services under the Act or the India-USA DTAA, because customers only availed services and did not acquire any right to use the assessee's infrastructure, software, or other assets for commercial exploitation. The Tribunal followed jurisdictional High Court and coordinate bench rulings, including Amazon Web Services, and deleted the addition for both assessment years. On TDS credit, the matter was remitted for verification, with directions to allow due credit and recompute interest and allied relief consequentially to the deletion of the substantive addition.
Receipts from SaaS-based product analytics services rendered to Indian customers were held not taxable as royalty or as fees for technical services/included services under the Act or the India-USA DTAA, because customers only availed services and did not acquire any right to use the assessee's infrastructure, software, or other assets for commercial exploitation. The Tribunal followed jurisdictional High Court and coordinate bench rulings, including Amazon Web Services, and deleted the addition for both assessment years. On TDS credit, the matter was remitted for verification, with directions to allow due credit and recompute interest and allied relief consequentially to the deletion of the substantive addition.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
