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...
Business Auxiliary Services - export of services or not - Marketing operations done by an assessee in India cannot be said to be at behest of any Indian customers - the services were held to be as having been delivered and/or used outside India and thus being export of services. - AT
Business Auxiliary Services - export of services or not - Marketing operations done by an assessee in India cannot be said to be at behest of any Indian customers - the services were held to be as having been delivered and/or used outside India and thus being export of services. - AT
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