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 assessee, a software solution provider, contested various transfer pricing adjustments and disallowances. Key points: Certain comparables were directed to be excluded due to functional differences, size incomparability, and segmental data differences. Economic/working capital adjustment was allowed following precedents. Disallowance u/s 14A read with Rule 8D was partly remitted for re-verification of interest-free funds and nexus with exempt income. Computation of deduction u/s 10A regarding exclusion of foreign currency expenditure and non-exclusion of delayed foreign remittances was restored for re-examination. The levy of interest u/s 234D was remitted for re-verification of refund status.
The assessee, a software solution provider, contested various transfer pricing adjustments and disallowances. Key points: Certain comparables were directed to be excluded due to functional differences, size incomparability, and segmental data differences. Economic/working capital adjustment was allowed following precedents. Disallowance u/s 14A read with Rule 8D was partly remitted for re-verification of interest-free funds and nexus with exempt income. Computation of deduction u/s 10A regarding exclusion of foreign currency expenditure and non-exclusion of delayed foreign remittances was restored for re-examination. The levy of interest u/s 234D was remitted for re-verification of refund status.
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TaxTMI 
TaxTMI 
of 4918 
