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...
TDS u/s 195 - for providing standard bandwith services - royalty or business income - The amount received by RJIPL from the assessee for providing standard bandwith services could not be characterised as ‘royalty’ as per the India- Singapore DTAA, and was in fact the “business profits”, which is not taxable as RJIPL did not have any business connection or a PE in India - No TDS
TDS u/s 195 - for providing standard bandwith services - royalty or business income - The amount received by RJIPL from the assessee for providing standard bandwith services could not be characterised as ‘royalty’ as per the India- Singapore DTAA, and was in fact the “business profits”, which is not taxable as RJIPL did not have any business connection or a PE in India - No TDS
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
