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...
Rate of tax applicable to PE of foreign entity - DTAA between India and Japan - by virtue of Clause 24(2) of the said agreement and the statutory recognition thereof in Section 90(2), the PE of a Japanese entity(bank) in India could not have been charged tax at a rate higher than comparable Indian assessees carrying on the same activities - taxable @ applicable on Indian bank
Rate of tax applicable to PE of foreign entity - DTAA between India and Japan - by virtue of Clause 24(2) of the said agreement and the statutory recognition thereof in Section 90(2), the PE of a Japanese entity(bank) in India could not have been charged tax at a rate higher than comparable Indian assessees carrying on the same activities - taxable @ applicable on Indian bank
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4921 
