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...
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In wholesale trading of auto and CNG components, comparables engaged in retail and after-sales trade were found functionally dissimilar under Rule 10B(2)(d), so the disputed entities were excluded and the remaining comparable kept the margin within the acceptable range; the transfer pricing adjustments for AY 2016-17 and AY 2017-18 were deleted. For transporter payments, the claimed non-deduction of tax turned on verification of a deductee certificate that had not been examined by the lower authorities, so the disallowance issue was remanded for fresh factual verification and adjudication.
In wholesale trading of auto and CNG components, comparables engaged in retail and after-sales trade were found functionally dissimilar under Rule 10B(2)(d), so the disputed entities were excluded and the remaining comparable kept the margin within the acceptable range; the transfer pricing adjustments for AY 2016-17 and AY 2017-18 were deleted. For transporter payments, the claimed non-deduction of tax turned on verification of a deductee certificate that had not been examined by the lower authorities, so the disallowance issue was remanded for fresh factual verification and adjudication.
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