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 income in India - Addition of receipt emanating from offshore supplies of escalators and elevators - The Appellate Tribunal observed that the consortium, comprising the appellant and another entity, had distinct and separate responsibilities delineated in the Memorandum of Understanding (MOU). The Tribunal emphasized that the income accrued to the appellant from offshore supplies, and as per relevant legal precedents, such income was not taxable in India. Therefore, the Tribunal directed the assessing officer to delete the addition made to the appellant's income.
Taxability of income in India - Addition of receipt emanating from offshore supplies of escalators and elevators - The Appellate Tribunal observed that the consortium, comprising the appellant and another entity, had distinct and separate responsibilities delineated in the Memorandum of Understanding (MOU). The Tribunal emphasized that the income accrued to the appellant from offshore supplies, and as per relevant legal precedents, such income was not taxable in India. Therefore, the Tribunal directed the assessing officer to delete the addition made to the appellant's income.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
