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...
Foreign Tax Credit (FTC) for default in filling Form 67 under Rule 128 - delay in compliance of a procedural provision - Rule 128(9) does not provide for disallowance of FTC in case of delay in filing Form No.67. - FTC cannot be denied to the assessee. Assessee is directed to file the relevant details/evidences in support of its claim. - AT
Foreign Tax Credit (FTC) for default in filling Form 67 under Rule 128 - delay in compliance of a procedural provision - Rule 128(9) does not provide for disallowance of FTC in case of delay in filing Form No.67. - FTC cannot be denied to the assessee. Assessee is directed to file the relevant details/evidences in support of its claim. - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
