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...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
Transfer pricing adjustment - agreement was between the Indian PSU and the Indian subsidiary of two non resident companies - transaction, cannot be presumed to be international transaction, even when the revenue authorities have tried to include it as the deemed transactions, - AT
Transfer pricing adjustment - agreement was between the Indian PSU and the Indian subsidiary of two non resident companies - transaction, cannot be presumed to be international transaction, even when the revenue authorities have tried to include it as the deemed transactions, - AT
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