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...
In a transfer pricing dispute, the ITAT addressed the appropriateness of the Resale Price Method (RPM) versus the Transactional Net Margin Method (TNMM). The tribunal found that the assessee's transactions involving purchase and sales were interconnected, rendering RPM the most appropriate method for benchmarking. The Dispute Resolution Panel's general observations were deemed insufficient, and the Transfer Pricing Officer was directed to reconsider the method. The tribunal concluded that the RPM method was justified for trading transactions, and the TNMM approach was not tenable given the complex nature of the assessee's international transactions.
In a transfer pricing dispute, the ITAT addressed the appropriateness of the Resale Price Method (RPM) versus the Transactional Net Margin Method (TNMM). The tribunal found that the assessee's transactions involving purchase and sales were interconnected, rendering RPM the most appropriate method for benchmarking. The Dispute Resolution Panel's general observations were deemed insufficient, and the Transfer Pricing Officer was directed to reconsider the method. The tribunal concluded that the RPM method was justified for trading transactions, and the TNMM approach was not tenable given the complex nature of the assessee's international transactions.
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TaxTMI 
TaxTMI 
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