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...
TDS u/s 195 - Liability to deduct tax on payments made on sub-contract work done - outsourcing a portion of on-site work to its subsidiary in China - Scope of amendment of Finance Act, 2010 in section 9 with retrospective effect - “person” mentioned in section 195 of the Income Tax Act cannot be expected to do the impossible - Order set aside - HC
TDS u/s 195 - Liability to deduct tax on payments made on sub-contract work done - outsourcing a portion of on-site work to its subsidiary in China - Scope of amendment of Finance Act, 2010 in section 9 with retrospective effect - “person” mentioned in section 195 of the Income Tax Act cannot be expected to do the impossible - Order set aside - HC
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