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...
Deduction u/s 80-O - Royalty - proof of rendering technical services - Appellant was a managing agent - the principal agent relationship between the parties established - there is no basis for grant of deduction to the Appellant under Section 80-O of the IT Act - SC
Deduction u/s 80-O - Royalty - proof of rendering technical services - Appellant was a managing agent - the principal agent relationship between the parties established - there is no basis for grant of deduction to the Appellant under Section 80-O of the IT Act - SC
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