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...
Professional fees paid for services linked to imports from OFAC-restricted Iranian-origin goods were held allowable under section 37(1) because the assessee proved the recipient's identity, genuineness of payment, and banking trail, while the payee confirmed the transactions and disclosed them in its tax records. The Tribunal accepted that the services addressed abnormal remittance delays caused by OFAC-related banking scrutiny, and that comparative material showed improved payment cycles, turnover, and profits after the services were used. Revenue's disallowance failed because it relied on suspicion without independent enquiry or evidence that the services were nonexistent or that payments were returned.
Professional fees paid for services linked to imports from OFAC-restricted Iranian-origin goods were held allowable under section 37(1) because the assessee proved the recipient's identity, genuineness of payment, and banking trail, while the payee confirmed the transactions and disclosed them in its tax records. The Tribunal accepted that the services addressed abnormal remittance delays caused by OFAC-related banking scrutiny, and that comparative material showed improved payment cycles, turnover, and profits after the services were used. Revenue's disallowance failed because it relied on suspicion without independent enquiry or evidence that the services were nonexistent or that payments were returned.
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TaxTMI 
TaxTMI 
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