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...
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Valuation of goods - Inclusion of lumpsum trademark fee and lumpsum royalty for technical knowhow - there is no stipulation or condition as to where from or from whom the appellant has to procure the raw materials for the manufacture of the goods - royalty not includible - AT
Valuation of goods - Inclusion of lumpsum trademark fee and lumpsum royalty for technical knowhow - there is no stipulation or condition as to where from or from whom the appellant has to procure the raw materials for the manufacture of the goods - royalty not includible - AT
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