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...
The High Court upheld the Income Tax Appellate Tribunal's (ITAT) decision regarding the applicability of Section 92(3) in determining the arm's length price for intra-group services. The ITAT correctly held that if the arm's length price is determined separately for multiple categories of international transactions, any transfer pricing adjustment for one transaction would necessitate an adjustment to the second category, resulting in reduced profits. The High Court found no legal grounds to challenge the ITAT's ruling, as accepting the appellant's contention would reduce the taxable income. Consequently, the appeal was dismissed as it failed to raise any substantial question of law.
The High Court upheld the Income Tax Appellate Tribunal's (ITAT) decision regarding the applicability of Section 92(3) in determining the arm's length price for intra-group services. The ITAT correctly held that if the arm's length price is determined separately for multiple categories of international transactions, any transfer pricing adjustment for one transaction would necessitate an adjustment to the second category, resulting in reduced profits. The High Court found no legal grounds to challenge the ITAT's ruling, as accepting the appellant's contention would reduce the taxable income. Consequently, the appeal was dismissed as it failed to raise any substantial question of law.
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