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...
TP adjustment regarding interest on outstanding receivables - “interest on receivables” is an international transaction during the FY and the decisions rendered prior to the amendment to section 92B are not applicable ipso facto applicable - when the credit period is clearly mentioned in the Agreement then the same only should be allowed and interest on trade receivables after such credit period should be computed for TP adjustment
TP adjustment regarding interest on outstanding receivables - “interest on receivables” is an international transaction during the FY and the decisions rendered prior to the amendment to section 92B are not applicable ipso facto applicable - when the credit period is clearly mentioned in the Agreement then the same only should be allowed and interest on trade receivables after such credit period should be computed for TP adjustment
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