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...
Extension of export obligation period - It is also well settled that the relaxation of the policy is not a matter of right - Sufficient discretion is granted to the PRC/DGFT to relax any provision of the policy or procedure as it deems fit - applicant must establish that his cause of hardship is on account of circumstances, which could not be reasonably anticipated by a person engaged in the trade
Extension of export obligation period - It is also well settled that the relaxation of the policy is not a matter of right - Sufficient discretion is granted to the PRC/DGFT to relax any provision of the policy or procedure as it deems fit - applicant must establish that his cause of hardship is on account of circumstances, which could not be reasonably anticipated by a person engaged in the trade
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