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...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
Replacement of dies and moulds was treated as revenue expenditure under current repairs principles, while temporary structural and interior works were accepted as non-enduring and not capital in nature. Weighted deduction for research expenditure on work in progress was allowed on the basis of earlier precedent. Entry tax remained deductible under income tax law despite set-off under sales tax law, and the discount on prepayment of deferred sales tax on an NPV basis was held capital, not income. Amounts paid to foreign entities for ECB-related services were not taxable under the applicable DTAA because the make-available test was not satisfied, so no TDS liability arose. Prior final orders on foreign commission disallowance were followed, and the appeal was dismissed.
Replacement of dies and moulds was treated as revenue expenditure under current repairs principles, while temporary structural and interior works were accepted as non-enduring and not capital in nature. Weighted deduction for research expenditure on work in progress was allowed on the basis of earlier precedent. Entry tax remained deductible under income tax law despite set-off under sales tax law, and the discount on prepayment of deferred sales tax on an NPV basis was held capital, not income. Amounts paid to foreign entities for ECB-related services were not taxable under the applicable DTAA because the make-available test was not satisfied, so no TDS liability arose. Prior final orders on foreign commission disallowance were followed, and the appeal was dismissed.
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TaxTMI 
TaxTMI 
of 4921 
