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...
Reference made to TPO - Transfer Price Adjustments (TPA) – Whether Section 92C and 92CA of the income tax act are independent of each other – the words "the said international transaction under section 92C" do not, lead to the conclusion that the requirement of section 92C(3) can be read into section 92CA(1) of the Act - AT
Reference made to TPO - Transfer Price Adjustments (TPA) – Whether Section 92C and 92CA of the income tax act are independent of each other – the words "the said international transaction under section 92C" do not, lead to the conclusion that the requirement of section 92C(3) can be read into section 92CA(1) of the Act - AT
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