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...
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Entitlement to benefits of treaty exemption - India-Singapore DTAA - Application of Section 172 - Taxation of shipping companies - The tribunal concluded that the arguments regarding the denial of tax treaty benefits and the condition of remittance required a re-evaluation of the evidence, particularly the letter from IRAS. Given the discrepancies and the need for further clarification, the tribunal remanded the matter to the Assessing Officer for detailed verification of the IRAS certificate and its implications on the assessee's tax liability under the India-Singapore DTAA.
Entitlement to benefits of treaty exemption - India-Singapore DTAA - Application of Section 172 - Taxation of shipping companies - The tribunal concluded that the arguments regarding the denial of tax treaty benefits and the condition of remittance required a re-evaluation of the evidence, particularly the letter from IRAS. Given the discrepancies and the need for further clarification, the tribunal remanded the matter to the Assessing Officer for detailed verification of the IRAS certificate and its implications on the assessee's tax liability under the India-Singapore DTAA.
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