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...
Commission paid to a non-resident agent for services rendered outside India was treated as not giving rise to income accruing or arising in India, so section 195 was held inapplicable and the related section 40(a)(i) disallowance could not stand. The Tribunal also sustained the deletion of disallowance on ocean freight paid to non-resident shipping lines or their agents, accepting that tax had already been deducted on payments to residents and that the balance freight was not liable for TDS in view of CBDT Circular No. 723. The Revenue produced no material to disturb the CIT(A)'s findings, so the appellate relief was affirmed.
Commission paid to a non-resident agent for services rendered outside India was treated as not giving rise to income accruing or arising in India, so section 195 was held inapplicable and the related section 40(a)(i) disallowance could not stand. The Tribunal also sustained the deletion of disallowance on ocean freight paid to non-resident shipping lines or their agents, accepting that tax had already been deducted on payments to residents and that the balance freight was not liable for TDS in view of CBDT Circular No. 723. The Revenue produced no material to disturb the CIT(A)'s findings, so the appellate relief was affirmed.
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TaxTMI 
TaxTMI 
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