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...
Service PE in India - India Singapore DTAA - Service PE or Not - the threshold of the time limit as calculated by the AO from the date of signing of agreement cannot be accepted. - the number of days is far below than 183 days - project does not constitute service PE in India - AT
Service PE in India - India Singapore DTAA - Service PE or Not - the threshold of the time limit as calculated by the AO from the date of signing of agreement cannot be accepted. - the number of days is far below than 183 days - project does not constitute service PE in India - AT
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