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...
TP Adjustment - Comparable selection - Merely because these companies have earned losses for the year under consideration would not lead to its exclusion without analysing as per rule 10 B (4) - DRP is to analyse the financials of immediately to preceding assessment years.
TP Adjustment - Comparable selection - Merely because these companies have earned losses for the year under consideration would not lead to its exclusion without analysing as per rule 10 B (4) - DRP is to analyse the financials of immediately to preceding assessment years.
Note: It is a system-generated summary and is for quick reference only.