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...
M/s. ASK Re Ltd., Hong Kong held as Associated Enterprise u/s 92A(2)(j). CUP method accepted as Most Appropriate Method, rejecting TNMM and TP adjustment. Disallowance u/s 14A read with Rule 8D deleted as no exempt income earned by assessee, relying on Era Infrastructure and Maxivision Eye Hospital cases. Assessee's appeals allowed on TP and 14A issues.
M/s. ASK Re Ltd., Hong Kong held as Associated Enterprise u/s 92A(2)(j). CUP method accepted as Most Appropriate Method, rejecting TNMM and TP adjustment. Disallowance u/s 14A read with Rule 8D deleted as no exempt income earned by assessee, relying on Era Infrastructure and Maxivision Eye Hospital cases. Assessee's appeals allowed on TP and 14A issues.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
