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...
Taxability of receipts from offshore supply of equipments - offshore supply made to Indian PSU’s which the assessee had claimed to be not chargeable to tax under Indian Taxation - Assessee company is tax resident of China - The Tribunal analyzed the terms of the contracts and previous tribunal decisions, which indicated that the transfer of title over the goods occurred outside India, making the receipts non-taxable in India. The court emphasized that the Assessing Officer's bifurcation lacked a rational basis and evidence, rendering it impermissible.
Taxability of receipts from offshore supply of equipments - offshore supply made to Indian PSU’s which the assessee had claimed to be not chargeable to tax under Indian Taxation - Assessee company is tax resident of China - The Tribunal analyzed the terms of the contracts and previous tribunal decisions, which indicated that the transfer of title over the goods occurred outside India, making the receipts non-taxable in India. The court emphasized that the Assessing Officer's bifurcation lacked a rational basis and evidence, rendering it impermissible.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
