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...
ITAT held that cross-border service fees between Bank A and Bank B relating to derivative trading constitute charges for services rendered to each bank's clients and were correctly treated as income of the recipient bank; the Assessing Officer erred in characterizing payments made by Bank B to Bank A as income of Bank B and in treating Bank B as in default for non-deduction of tax at source under section 195. The impugned additions were found without merit, and the AO was directed to delete those additions. All effective grounds raised by the assessee were allowed, resulting in complete relief on the TDS and income-characterisation issues.
ITAT held that cross-border service fees between Bank A and Bank B relating to derivative trading constitute charges for services rendered to each bank's clients and were correctly treated as income of the recipient bank; the Assessing Officer erred in characterizing payments made by Bank B to Bank A as income of Bank B and in treating Bank B as in default for non-deduction of tax at source under section 195. The impugned additions were found without merit, and the AO was directed to delete those additions. All effective grounds raised by the assessee were allowed, resulting in complete relief on the TDS and income-characterisation issues.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
