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...
Foreign exchange gain/loss treated as non-operative for assessee and comparables due to risk mitigation by associated enterprises. Safe Harbor Rules not applicable as assessee not determined eligible. Inconsistent approach by TPO in treating forex gain/loss as operating for comparables rejected. Case laws distinguishable due to risk borne by assessee. Zenith Computers excluded as persistent loss-making company. Whirlpool and Penguin excluded as functionally dissimilar from mobile phone manufacturing. For CSD segment, Infobeans Technologies, Persistent Systems, L&T Infotech, and Mindtree excluded due to functional dissimilarity or lack of segmental data. Dividend distribution tax payable at rate u/s 115O, not DTAA rate, unless DTAA expressly extends benefit to domestic company. Appeal partly allowed.
Foreign exchange gain/loss treated as non-operative for assessee and comparables due to risk mitigation by associated enterprises. Safe Harbor Rules not applicable as assessee not determined eligible. Inconsistent approach by TPO in treating forex gain/loss as operating for comparables rejected. Case laws distinguishable due to risk borne by assessee. Zenith Computers excluded as persistent loss-making company. Whirlpool and Penguin excluded as functionally dissimilar from mobile phone manufacturing. For CSD segment, Infobeans Technologies, Persistent Systems, L&T Infotech, and Mindtree excluded due to functional dissimilarity or lack of segmental data. Dividend distribution tax payable at rate u/s 115O, not DTAA rate, unless DTAA expressly extends benefit to domestic company. Appeal partly allowed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
