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...
Scientific and Technical Consultancy Service - In-house training M/s SMC, Japan does not covered under Scientific and Technical Consultancy Service in terms of Section 65 (95a) of the Finance Act, 1994 - the appellant is not liable to pay interest for the intervening period i.e. date of service provided till its realization. - AT
Scientific and Technical Consultancy Service - In-house training M/s SMC, Japan does not covered under Scientific and Technical Consultancy Service in terms of Section 65 (95a) of the Finance Act, 1994 - the appellant is not liable to pay interest for the intervening period i.e. date of service provided till its realization. - AT
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