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...
Income from sale of shrink wrap software - consideration received by the Assessee for software was not royalty. The receipts would constitute business receipts in the hands of the Assessee - Assessee cannot be taxed in India in the absence of a permanent establishment - AT
Income from sale of shrink wrap software - consideration received by the Assessee for software was not royalty. The receipts would constitute business receipts in the hands of the Assessee - Assessee cannot be taxed in India in the absence of a permanent establishment - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4921 
