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...
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Reverse Charge Mechanism - Scope of Service tax act - period of dispute is the FY 2005-06 - Section 66A ibid has been inserted in the Statute w.e.f. 18.04.2006 providing for levy of service tax on reverse charge basis on the services procured from outside India - hence no service tax can be demanded for the period upto 17.04.2006
Reverse Charge Mechanism - Scope of Service tax act - period of dispute is the FY 2005-06 - Section 66A ibid has been inserted in the Statute w.e.f. 18.04.2006 providing for levy of service tax on reverse charge basis on the services procured from outside India - hence no service tax can be demanded for the period upto 17.04.2006
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