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...
TP Adjustment - writ against DRP order - admission of additional documents and seek a remand report from the AO can only mean that the panel was of the view that further examination of the issue by the Department was called for - if not satisfied with remand report of TPO, Panel could well have sought a clarification, or directed the officer to carry out further verification - remanded for de novo decision of DRP
TP Adjustment - writ against DRP order - admission of additional documents and seek a remand report from the AO can only mean that the panel was of the view that further examination of the issue by the Department was called for - if not satisfied with remand report of TPO, Panel could well have sought a clarification, or directed the officer to carry out further verification - remanded for de novo decision of DRP
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