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...
Attribution of profit to PE qua the offshore supply of plants and equipments - Attribution of profit to PE qua the offshore supply of plants and equipments - Additions made by AO deleted - AO directed to attribute 1% of the receipts from offshore supply of equipment as profit of the PE and accordingly compute the income of the assessee. - AT
Attribution of profit to PE qua the offshore supply of plants and equipments - Attribution of profit to PE qua the offshore supply of plants and equipments - Additions made by AO deleted - AO directed to attribute 1% of the receipts from offshore supply of equipment as profit of the PE and accordingly compute the income of the assessee. - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
