Reassessment disclosure requirements permit stated reasons without revealing information sources, but prior-taxation claims require full examination b...
Independent assessment discretion and corroborated electronic evidence determine validity of on-money additions and undisclosed-consideration assessme...
Rectification of DRP directions that changed AMP benchmarking from the earlier approach to intensity-adjusted TNMM, on the CIT(DR)'s application, was unsustainable; the rectified directions and consequential assessment order were set aside. Original DRP directions requiring deletion of a protective AMP adjustment bound the assessment proceedings, so the protective adjustment based on the Bright Line Test was also set aside. AMP transfer-pricing adjustments derived through both the Bright Line Test and intensity-adjusted TNMM were unsustainable for the relevant year and corresponding subsequent years. The impugned assessment orders were set aside, while academic, consequential and unpressed grounds remained open or were not pressed.
Rectification of DRP directions that changed AMP benchmarking from the earlier approach to intensity-adjusted TNMM, on the CIT(DR)'s application, was unsustainable; the rectified directions and consequential assessment order were set aside. Original DRP directions requiring deletion of a protective AMP adjustment bound the assessment proceedings, so the protective adjustment based on the Bright Line Test was also set aside. AMP transfer-pricing adjustments derived through both the Bright Line Test and intensity-adjusted TNMM were unsustainable for the relevant year and corresponding subsequent years. The impugned assessment orders were set aside, while academic, consequential and unpressed grounds remained open or were not pressed.
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