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...
Composite cargo handling classification turned on the contract's essential character: arranging containers, loading, multi-modal movement, freight coordination and delivery assurance together formed an integrated cargo handling service, so transport was only incidental. Separate invoicing, use of contractors, and the earlier order in the appellant's own case did not alter classification, especially after the widened definition from 16.05.2008. The Tribunal also upheld the extended period and penalties because several service components were excluded from the taxable value, resulting in short-payment on the full gross value.
Composite cargo handling classification turned on the contract's essential character: arranging containers, loading, multi-modal movement, freight coordination and delivery assurance together formed an integrated cargo handling service, so transport was only incidental. Separate invoicing, use of contractors, and the earlier order in the appellant's own case did not alter classification, especially after the widened definition from 16.05.2008. The Tribunal also upheld the extended period and penalties because several service components were excluded from the taxable value, resulting in short-payment on the full gross value.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
