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 194I or 194C - storage charges paid by assessee - TDS @ 20% - The ITAT concluded that assessee is liable to deduct Tax at Source u/s 194C - The High court determined that the storage tanks in question did not qualify as land or building under Section 194I of the Act. It concluded that the payments made by the assessee were not subject to tax deduction at source under Section 194I. - The court upheld the decision of the ITAT, disposing of the appeals in favor of the assessee.
TDS u/s 194I or 194C - storage charges paid by assessee - TDS @ 20% - The ITAT concluded that assessee is liable to deduct Tax at Source u/s 194C - The High court determined that the storage tanks in question did not qualify as land or building under Section 194I of the Act. It concluded that the payments made by the assessee were not subject to tax deduction at source under Section 194I. - The court upheld the decision of the ITAT, disposing of the appeals in favor of the assessee.
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