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 u/s 40A(2) r.w.s 37 - management fee - Neither the TPO nor the AO have brought any material on record indicating the assessee’s excessive impugned payments as the statutory provision in question is applicable only for excessive component of the relevant heads of the expenditure than that in entirety - the CIT(A) action deleting the upward adjustment is affirmed
TP Adjustment u/s 40A(2) r.w.s 37 - management fee - Neither the TPO nor the AO have brought any material on record indicating the assessee’s excessive impugned payments as the statutory provision in question is applicable only for excessive component of the relevant heads of the expenditure than that in entirety - the CIT(A) action deleting the upward adjustment is affirmed
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TaxTMI 
TaxTMI 
of 4918 
