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...
TP Adjustment - benchmarking of transaction - the margin shown by the assessee of gross profit is 15.35% compared to the comparable companies of 14.60% we direct the learned transfer pricing officer/AO to delete the consequent adjustment - AT
TP Adjustment - benchmarking of transaction - the margin shown by the assessee of gross profit is 15.35% compared to the comparable companies of 14.60% we direct the learned transfer pricing officer/AO to delete the consequent adjustment - AT
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