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...
In a transfer pricing dispute, the Tribunal held that Onward Technologies Ltd. remained a valid comparable for benchmarking the engineering, technical and inspection services segment because the TPO/AO had accepted its segmental results and the CIT(A) had also upheld that position. The Revenue's attempt to seek exclusion of the company as functionally not comparable was rejected as misconceived, since the objection was raised for the first time before the Tribunal after acceptance at the earlier stages. The additional grounds were therefore dismissed, and the Revenue's appeal failed.
In a transfer pricing dispute, the Tribunal held that Onward Technologies Ltd. remained a valid comparable for benchmarking the engineering, technical and inspection services segment because the TPO/AO had accepted its segmental results and the CIT(A) had also upheld that position. The Revenue's attempt to seek exclusion of the company as functionally not comparable was rejected as misconceived, since the objection was raised for the first time before the Tribunal after acceptance at the earlier stages. The additional grounds were therefore dismissed, and the Revenue's appeal failed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
