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...
Addition on account of IPCL/link charges - the payment is in the nature of reimbursement of expenses and accordingly not taxable in the hands of the assessee - said payments do not constitute Royalty under the provisions of Article 12 of the tax treaty - AT
Addition on account of IPCL/link charges - the payment is in the nature of reimbursement of expenses and accordingly not taxable in the hands of the assessee - said payments do not constitute Royalty under the provisions of Article 12 of the tax treaty - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
