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...
Export of services or not - place of consumption of services - the customers of foreign entity are located in India and assessee are receiving the commission in respect of the goods of these foreign entities sold by them in India. Thus services provided by the appellant facilitate the conduct of business of the Foreign Entities in India - Cannot be held as export of services.
Export of services or not - place of consumption of services - the customers of foreign entity are located in India and assessee are receiving the commission in respect of the goods of these foreign entities sold by them in India. Thus services provided by the appellant facilitate the conduct of business of the Foreign Entities in India - Cannot be held as export of services.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
