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 made on account of payment of management charges - Proof of availment of services - the payment made by the assessee being cost to cost reimbursement of the services availed from common pool is duly allowable as a business expenditure in the hands of the assessee. - TPO has exceeded his jurisdiction in holding the value of the said international transaction at NIL. - AT
TP adjustment made on account of payment of management charges - Proof of availment of services - the payment made by the assessee being cost to cost reimbursement of the services availed from common pool is duly allowable as a business expenditure in the hands of the assessee. - TPO has exceeded his jurisdiction in holding the value of the said international transaction at NIL. - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
