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 - TNMM VS RPM - neither the TPO nor learned DRP has pointed out any other defect in the transfer pricing analysis of the assessee except that the assessee is involved in manufacturing activity - bench marking done by the assessee under RPM has to be accepted more so, when the TPO has accepted the comparables selected by the assessee
TP adjustment - TNMM VS RPM - neither the TPO nor learned DRP has pointed out any other defect in the transfer pricing analysis of the assessee except that the assessee is involved in manufacturing activity - bench marking done by the assessee under RPM has to be accepted more so, when the TPO has accepted the comparables selected by the assessee
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