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...
Penalty u/s 271G - assessee applied TNMM for determining of ALP - information/documents sought for determining of ALP as per CUP method - the difficulty in maintaining the information sought by the TPO has been well explained and analysed - allegation of the TPO that by non furnishing of documents has prevented him from determining the ALP under CUP method is unacceptable when he has accepted the benchmarking of the assessee - no penalty
Penalty u/s 271G - assessee applied TNMM for determining of ALP - information/documents sought for determining of ALP as per CUP method - the difficulty in maintaining the information sought by the TPO has been well explained and analysed - allegation of the TPO that by non furnishing of documents has prevented him from determining the ALP under CUP method is unacceptable when he has accepted the benchmarking of the assessee - no penalty
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
