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 - India-UAE DTAA - payments made to Dubai Leading Technologies - It is business transaction and not in the nature of Fee for Technical Services (FTS) - there is no obligation to deduct tax at source under section 195 of the Act as the impugned payments are not chargeable to tax in India - AT
TDS u/s 195 - India-UAE DTAA - payments made to Dubai Leading Technologies - It is business transaction and not in the nature of Fee for Technical Services (FTS) - there is no obligation to deduct tax at source under section 195 of the Act as the impugned payments are not chargeable to tax in India - AT
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