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...
Where a draft assessment order is issued within the prescribed period, final assessment timing pursuant to DRP directions follows the specific statutory limits rather than the general assessment limitation. Tax computation must give effect to allowed brought-forward losses and unabsorbed depreciation, subject to verification against duplicate relief. RPM is appropriate for unaltered goods resold to independent customers where reliable gross-profit data and functional comparability exist; operating profit or loss alone does not disqualify a trading comparable. The other method can combine justified NAV and DCF valuations, and a deemed international transaction does not establish associated-enterprise status for secondary adjustment, which requires the actual relationship.
Where a draft assessment order is issued within the prescribed period, final assessment timing pursuant to DRP directions follows the specific statutory limits rather than the general assessment limitation. Tax computation must give effect to allowed brought-forward losses and unabsorbed depreciation, subject to verification against duplicate relief. RPM is appropriate for unaltered goods resold to independent customers where reliable gross-profit data and functional comparability exist; operating profit or loss alone does not disqualify a trading comparable. The other method can combine justified NAV and DCF valuations, and a deemed international transaction does not establish associated-enterprise status for secondary adjustment, which requires the actual relationship.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
