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...
Valuation - inclusion of technical know - the original authority finds that 15% of marks up are added to cover the expenses and profit margin and therefore the relation has not influenced the prices hence there is no justification for inclusion of royalty and technical know-how in the assessable value of the imported products
Valuation - inclusion of technical know - the original authority finds that 15% of marks up are added to cover the expenses and profit margin and therefore the relation has not influenced the prices hence there is no justification for inclusion of royalty and technical know-how in the assessable value of the imported products
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