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 - comparability - under Rule 10B(2)(b), the comparability of an international transaction with an uncontrolled transaction shall be judged, among other factors, with reference to the functions performed, taking into account assets employed or to be employed and risks assumed by the respective parties to the transactions. - AT
TP Adjustment - comparability - under Rule 10B(2)(b), the comparability of an international transaction with an uncontrolled transaction shall be judged, among other factors, with reference to the functions performed, taking into account assets employed or to be employed and risks assumed by the respective parties to the transactions. - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
