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...
Income deemed to accrue or arise in India - receipts of subscription fees - The ITAT had found that it did not involve the transfer of copyright or the provision of technical or consultancy services that make available technical knowledge or processes to the subscriber. - The High court agreed with the Tribunal's decision, emphasizing that the provision of access to a legal database does not constitute the rendering of any technical or consultancy service that would make technical knowledge, experience, skill, know-how, or processes available to the subscriber, thereby not falling within the ambit of FTS as defined by the relevant DTAA and the Act.
Income deemed to accrue or arise in India - receipts of subscription fees - The ITAT had found that it did not involve the transfer of copyright or the provision of technical or consultancy services that make available technical knowledge or processes to the subscriber. - The High court agreed with the Tribunal's decision, emphasizing that the provision of access to a legal database does not constitute the rendering of any technical or consultancy service that would make technical knowledge, experience, skill, know-how, or processes available to the subscriber, thereby not falling within the ambit of FTS as defined by the relevant DTAA and the Act.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
