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...
Reopening of assessment - non deduction of tds on payment credit to foreign companies, on account of ‘software services‘ - there remained no omission or failure on the part of the assessee to disclose truly and fully all material facts - reassessment proceedings set aside - HC
Reopening of assessment - non deduction of tds on payment credit to foreign companies, on account of ‘software services‘ - there remained no omission or failure on the part of the assessee to disclose truly and fully all material facts - reassessment proceedings set aside - HC
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