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...
Transfer pricing adjustment - TNMM method required comparison of net profit margin realized from international transactions or aggregate of international transactions and not comparison of operating margins of the enterprises. - AT
Transfer pricing adjustment - TNMM method required comparison of net profit margin realized from international transactions or aggregate of international transactions and not comparison of operating margins of the enterprises. - AT
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