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 - includibility - non-reimbursed portion of the cost of transportation of inputs - If there is some additional consideration for sale, then such additional consideration also has to be included to the transaction value to determine the assessable value. This is precisely what the appellant had done. The Department cannot add separately all the costs incurred by the appellant which have not been reimbursed by the buyer in addition to the price. - AT
Valuation - includibility - non-reimbursed portion of the cost of transportation of inputs - If there is some additional consideration for sale, then such additional consideration also has to be included to the transaction value to determine the assessable value. This is precisely what the appellant had done. The Department cannot add separately all the costs incurred by the appellant which have not been reimbursed by the buyer in addition to the price. - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
