Assessing Officer jurisdiction after statutory transfer invalidates reassessment notices issued by transferor officers and nullifies resulting proceed...
Consequential appeal-effect orders must implement rectification deleting working-capital adjustments and reconsider the resulting arm's-length range c...
Discounted cash flow valuation protects share premium where projections are reasonable, while audited book expenses defeat unexplained-expenditure add...
Section 54 construction relief survives pre-transfer commencement when completion occurs within the statutory period, excluding ineligible spouse-owne...
Fraud classification show-cause notices founded on inconclusive forensic audit material cannot sustain action, permitting fresh proceedings on conclus...
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DRP directions bind the final assessment order, but a patent computation omission may be rectified within the statutory period where the directions were reproduced but not implemented. An Indian subsidiary does not create a permanent establishment merely on facts previously found insufficient to establish one, so no business-profit attribution follows on that basis. Third-party cost reimbursements received without mark-up are not fees for included services unless the services are technical or consultancy services and make available the requisite technical knowledge or know-how under the India-USA DTAA. Corporate guarantee commission must be benchmarked on the taxpayer's facts; a fixed formula without examining the taxpayer's benchmarking is inappropriate.
DRP directions bind the final assessment order, but a patent computation omission may be rectified within the statutory period where the directions were reproduced but not implemented. An Indian subsidiary does not create a permanent establishment merely on facts previously found insufficient to establish one, so no business-profit attribution follows on that basis. Third-party cost reimbursements received without mark-up are not fees for included services unless the services are technical or consultancy services and make available the requisite technical knowledge or know-how under the India-USA DTAA. Corporate guarantee commission must be benchmarked on the taxpayer's facts; a fixed formula without examining the taxpayer's benchmarking is inappropriate.
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