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...
Intra-group software licence costs are examined through inter-company invoices, third-party licensing agreements, allocation workings and supporting invoices to establish actual availing and the allocation basis for arm's length pricing. The notes state that a nil arm's length price was not justified where this evidence was furnished. For low-end IS&T services, Dispute Resolution Panel directions require verification of segmental audited revenue and recomputation of operating margins; cost-to-cost IT reimbursements must be treated consistently with those directions. Eclerx Services Ltd. is identified as functionally and operationally incomparable. Reversal of a previously disallowed bonus provision requires verification before deduction, and a pending rectification application must be decided before a fresh order.
Intra-group software licence costs are examined through inter-company invoices, third-party licensing agreements, allocation workings and supporting invoices to establish actual availing and the allocation basis for arm's length pricing. The notes state that a nil arm's length price was not justified where this evidence was furnished. For low-end IS&T services, Dispute Resolution Panel directions require verification of segmental audited revenue and recomputation of operating margins; cost-to-cost IT reimbursements must be treated consistently with those directions. Eclerx Services Ltd. is identified as functionally and operationally incomparable. Reversal of a previously disallowed bonus provision requires verification before deduction, and a pending rectification application must be decided before a fresh order.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
