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...
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Income accrued or deemed to accrue or arise in India - Royalty - the BREW Operator Software agreements - an application development platform - The royalty from BREW operator agreement is not chargeable to tax in the hands of the assessee and also the revenue received under the test tools agreement - AT
Income accrued or deemed to accrue or arise in India - Royalty - the BREW Operator Software agreements - an application development platform - The royalty from BREW operator agreement is not chargeable to tax in the hands of the assessee and also the revenue received under the test tools agreement - AT
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