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 - Assessee contents that part of the Revenue reported in future years, but the contention of the assessee cannot be accepted for the simple reason that when the assessee is following mercantile system of accounting, Revenue should be recognized as and when income accrues and arises to the assessee, irrespective of the fact that the assessee has received the income or not. - there is no error in the reasons given by the AO/DRP to make additions towards billing in excess of Revenue - AT
TP Adjustment - Assessee contents that part of the Revenue reported in future years, but the contention of the assessee cannot be accepted for the simple reason that when the assessee is following mercantile system of accounting, Revenue should be recognized as and when income accrues and arises to the assessee, irrespective of the fact that the assessee has received the income or not. - there is no error in the reasons given by the AO/DRP to make additions towards billing in excess of Revenue - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
