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...
Income accrued in India - Royalty receipt - Fees for Technical Services on accrual basis - the FTS is taxable only in the year of receipt as per the provisions of DTAA. - Tax authorities are not justified in assessing the impugned income on accrual basis. - AT
Income accrued in India - Royalty receipt - Fees for Technical Services on accrual basis - the FTS is taxable only in the year of receipt as per the provisions of DTAA. - Tax authorities are not justified in assessing the impugned income on accrual basis. - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
