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 - interest charged on foreign currency loan - The Tribunal ruled in favor of the Assessee, finding that the interest charged on the loan to its Associated Enterprise was at an arm's length rate. As a result, the appeal of the Assessee was allowed, and the addition sustained by the CIT(A) was directed to be deleted.
TP Adjustment - interest charged on foreign currency loan - The Tribunal ruled in favor of the Assessee, finding that the interest charged on the loan to its Associated Enterprise was at an arm's length rate. As a result, the appeal of the Assessee was allowed, and the addition sustained by the CIT(A) was directed to be deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
