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...
Valuation - inclusion of royalty charges in the assessable value - Royalty Charges is shown as Sales & Distribution overhead in the appellant’s books of account. This itself proves that the Royalty Charges is indeed included in the transaction value - Demand set aside.
Valuation - inclusion of royalty charges in the assessable value - Royalty Charges is shown as Sales & Distribution overhead in the appellant’s books of account. This itself proves that the Royalty Charges is indeed included in the transaction value - Demand set aside.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
