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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Transfer pricing adjustment - adjustment to the arm’s length price of the advertisement services received from the associated enterprise - Since the agreement is also silent, we do not accept that the assessee could utilize the basket of adslots and aggregate the same for achieving the target. - AT
Transfer pricing adjustment - adjustment to the arm’s length price of the advertisement services received from the associated enterprise - Since the agreement is also silent, we do not accept that the assessee could utilize the basket of adslots and aggregate the same for achieving the target. - AT
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