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...
Corporate guarantee commission was allocated only in part where the guarantee to the foreign associated enterprise's lenders was jointly furnished by the assessee and its subsidiary; on that basis, only 0.25% was attributable to the assessee. Interest disallowance on borrowed capital was not sustained for non-interest-bearing advances to AAIPL because the advances were made in the course of the real estate business and the decision to waive interest was commercially expedient to protect business interests and principal exposure. The same commercial expediency principle applied to advances to SCA LLP after the assessee became the majority partner with management control, making the funding commercially driven and not a basis for disallowing corresponding interest.
Corporate guarantee commission was allocated only in part where the guarantee to the foreign associated enterprise's lenders was jointly furnished by the assessee and its subsidiary; on that basis, only 0.25% was attributable to the assessee. Interest disallowance on borrowed capital was not sustained for non-interest-bearing advances to AAIPL because the advances were made in the course of the real estate business and the decision to waive interest was commercially expedient to protect business interests and principal exposure. The same commercial expediency principle applied to advances to SCA LLP after the assessee became the majority partner with management control, making the funding commercially driven and not a basis for disallowing corresponding interest.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
