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...
Rectification u/s 154 - treating certain non–operating expenses as operating in nature - difference in the rate of depreciation between itself and the comparables - the issue relating to the incorrect computation of margin of the comparables constitutes a mistake apparent on the face of record - directed the TPO to dispose of the application u/s 154 on merits
Rectification u/s 154 - treating certain non–operating expenses as operating in nature - difference in the rate of depreciation between itself and the comparables - the issue relating to the incorrect computation of margin of the comparables constitutes a mistake apparent on the face of record - directed the TPO to dispose of the application u/s 154 on merits
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TaxTMI 
TaxTMI 
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