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...
Taxability of income in India - deduction with respect to salaries paid by appellant in foreign currency outside India to expatriates working in India - Indo-Japan tax treaty. Following Emirates Commercial Bank Ltd. and Supreme Court's view in Goetze (India) Ltd., exception carved out for statutory prohibition of deduction claimed outside Return of Income not applicable in case of Tribunal or Court direction. HC quashed order denying relief to petitioner regarding deductions liable pursuant to Tribunal order.
Taxability of income in India - deduction with respect to salaries paid by appellant in foreign currency outside India to expatriates working in India - Indo-Japan tax treaty. Following Emirates Commercial Bank Ltd. and Supreme Court's view in Goetze (India) Ltd., exception carved out for statutory prohibition of deduction claimed outside Return of Income not applicable in case of Tribunal or Court direction. HC quashed order denying relief to petitioner regarding deductions liable pursuant to Tribunal order.
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TaxTMI 
TaxTMI 
of 4918 
