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 dismissed Revenue's appeals, upholding taxation of the assessee's receipts under Section 44BB rather than as FTS under Section 9(1)(vii) r.w.s. 44DA, following judicial consistency with earlier years in the assessee's own case. On offshore sale of equipment, ITAT accepted the assessee's 2% profit attribution for Indian operations, relying on prior coordinate bench findings that the assessee's selected comparables satisfied FAR analysis and yielded a weighted average margin of 1.69%. Consequently, no further profit attribution was warranted and AO was directed to accept the 2% margin.
ITAT dismissed Revenue's appeals, upholding taxation of the assessee's receipts under Section 44BB rather than as FTS under Section 9(1)(vii) r.w.s. 44DA, following judicial consistency with earlier years in the assessee's own case. On offshore sale of equipment, ITAT accepted the assessee's 2% profit attribution for Indian operations, relying on prior coordinate bench findings that the assessee's selected comparables satisfied FAR analysis and yielded a weighted average margin of 1.69%. Consequently, no further profit attribution was warranted and AO was directed to accept the 2% margin.
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TaxTMI 
TaxTMI 
of 4918 
