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...
Taxability of receipts on hire of vessel on a time charter basis - Royalty receipts u/s 9(1)(vi) - Addition on the ground that Charter has option of making structural alterations to the vessel and therefore, the charterer has specific control upon the vessel for its business activities. - ITAT dismissed the argument, as the clause also stated that the vessel would be returned to its original condition at the charterer's expense and the repairs could also be undertaken by the assessee. Therefore, the vessel was under the exclusive control and command of the assessee throughout the operation, navigation, and management. - AT
Taxability of receipts on hire of vessel on a time charter basis - Royalty receipts u/s 9(1)(vi) - Addition on the ground that Charter has option of making structural alterations to the vessel and therefore, the charterer has specific control upon the vessel for its business activities. - ITAT dismissed the argument, as the clause also stated that the vessel would be returned to its original condition at the charterer's expense and the repairs could also be undertaken by the assessee. Therefore, the vessel was under the exclusive control and command of the assessee throughout the operation, navigation, and management. - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
