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...
Consequential transfer pricing orders were held time-barred because the limitation period depended on the nature of the earlier appellate directions. Where the prior Tribunal order sent the issues on advances to associated enterprises and interest on outstanding receivables back for verification, hearing, and application of directions, the matter was treated as a fresh assessment on remand under section 153(3), with the second proviso to section 153(5) leading to the same result. Where the arm's length commission on corporate guarantees had already been conclusively fixed at 0.5% and only implementation remained, section 153(5) applied. In both situations, the consequential orders passed on 06.12.2024 were beyond time and were set aside.
Consequential transfer pricing orders were held time-barred because the limitation period depended on the nature of the earlier appellate directions. Where the prior Tribunal order sent the issues on advances to associated enterprises and interest on outstanding receivables back for verification, hearing, and application of directions, the matter was treated as a fresh assessment on remand under section 153(3), with the second proviso to section 153(5) leading to the same result. Where the arm's length commission on corporate guarantees had already been conclusively fixed at 0.5% and only implementation remained, section 153(5) applied. In both situations, the consequential orders passed on 06.12.2024 were beyond time and were set aside.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
