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...
Maintainability of appeal before CIT(A) - Refund of excess TDS deducted - withholding of taxes - assessee has deducted tax at source at higher rate of 20% in the absence of PAN of the deductee (Non resident) - Applicable TDS rate u/s 195 read with section 115A and Section 206AA - We hold that the deductor can challenge excess deduction u/s. 248 seeking that the rate of tax should be as per DTAA and not as per Section 206AA, if it is found that otherwise income is chargeable to tax in India and then certainly an appeal would be maintainable u/s. 248 seeking relief/refund for excess tax deducted. - AT
Maintainability of appeal before CIT(A) - Refund of excess TDS deducted - withholding of taxes - assessee has deducted tax at source at higher rate of 20% in the absence of PAN of the deductee (Non resident) - Applicable TDS rate u/s 195 read with section 115A and Section 206AA - We hold that the deductor can challenge excess deduction u/s. 248 seeking that the rate of tax should be as per DTAA and not as per Section 206AA, if it is found that otherwise income is chargeable to tax in India and then certainly an appeal would be maintainable u/s. 248 seeking relief/refund for excess tax deducted. - AT
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TaxTMI 
TaxTMI 
of 4918 
