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...
A registered recipient may seek an advance ruling where the transaction affects its tax position, because the term "applicant" is broad enough to cover such a request; the locus objection was therefore rejected and the ruling was examined on merits. On classification, crushing, screening and sizing of limestone/dolomite did not amount to manufacture because the processes did not produce a new product with a distinct name, character and use; the mineral identity and commercial understanding remained unchanged, with only physical dimensions altered. The contractor's assumption of operational risk was irrelevant. The activity was treated as treatment or processing of another person's goods and therefore a supply of service in the nature of job work.
A registered recipient may seek an advance ruling where the transaction affects its tax position, because the term "applicant" is broad enough to cover such a request; the locus objection was therefore rejected and the ruling was examined on merits. On classification, crushing, screening and sizing of limestone/dolomite did not amount to manufacture because the processes did not produce a new product with a distinct name, character and use; the mineral identity and commercial understanding remained unchanged, with only physical dimensions altered. The contractor's assumption of operational risk was irrelevant. The activity was treated as treatment or processing of another person's goods and therefore a supply of service in the nature of job work.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
