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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PILCOM was treated as only a managing committee for the World Cup, not an independent assessable entity or association of persons, so the protective additions could not stand. The Tribunal held that receipts and relating to matches in India, and the common receipts already covered in the assessee's accounts and return under the agreed financial arrangement, could not be separately taxed again in PILCOM's hands. It also held that amounts linked to matches outside India were not taxable on a protective basis where the assessee neither received nor was entitled to receive them. The Revenue's appeal failed and the deletion of the protective assessment was upheld.
PILCOM was treated as only a managing committee for the World Cup, not an independent assessable entity or association of persons, so the protective additions could not stand. The Tribunal held that receipts and relating to matches in India, and the common receipts already covered in the assessee's accounts and return under the agreed financial arrangement, could not be separately taxed again in PILCOM's hands. It also held that amounts linked to matches outside India were not taxable on a protective basis where the assessee neither received nor was entitled to receive them. The Revenue's appeal failed and the deletion of the protective assessment was upheld.
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