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...
TDS u/s 195 - royalty payments or not - Consideration for advertisement is paid to the overseas bank account of Non-resident - the payments made by the assessee the non-resident company M/s. Facebook, Ireland cannot be considered ad "royalty payments" - There is no requirement to deduct tax at source from those payments u/s. 195 - Hence the assessee herein cannot be considered as an assessee in default u/s. 201(1) of the Act. - AT
TDS u/s 195 - royalty payments or not - Consideration for advertisement is paid to the overseas bank account of Non-resident - the payments made by the assessee the non-resident company M/s. Facebook, Ireland cannot be considered ad "royalty payments" - There is no requirement to deduct tax at source from those payments u/s. 195 - Hence the assessee herein cannot be considered as an assessee in default u/s. 201(1) of the Act. - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
