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...
Revenue-sharing under a participative railway infrastructure arrangement was treated as a joint venture-like model, not as business support service, because freight collections were shared as a return on capital investment with profit and not as consideration for any identified service. The text notes that there was no service provider-recipient relationship or direct quid pro quo, so the demand on that footing was not sustainable. It also records that a bona fide belief, supported by prior Tribunal rulings on similar arrangements, defeated suppression, making the extended limitation period unavailable.
Revenue-sharing under a participative railway infrastructure arrangement was treated as a joint venture-like model, not as business support service, because freight collections were shared as a return on capital investment with profit and not as consideration for any identified service. The text notes that there was no service provider-recipient relationship or direct quid pro quo, so the demand on that footing was not sustainable. It also records that a bona fide belief, supported by prior Tribunal rulings on similar arrangements, defeated suppression, making the extended limitation period unavailable.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
