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...
TP - the conclusion of the TPO that the arms length price of the royalty payment should be NIL without specifying any cogent basis is not sustainable - TPO's determination is on the basis of assumption and surmises. - AT
TP - the conclusion of the TPO that the arms length price of the royalty payment should be NIL without specifying any cogent basis is not sustainable - TPO's determination is on the basis of assumption and surmises. - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
