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...
Functional comparability under TNMM requires selection or exclusion of comparables to conform to Rule 10B through a factual, data-driven analysis. A standard departmental comparable set cannot replace appropriately matched companies. Software product, product-development, licence and subscription businesses with significant intangibles may be functionally dissimilar to a software development service provider and therefore unsuitable as comparables.
Functional comparability under TNMM requires selection or exclusion of comparables to conform to Rule 10B through a factual, data-driven analysis. A standard departmental comparable set cannot replace appropriately matched companies. Software product, product-development, licence and subscription businesses with significant intangibles may be functionally dissimilar to a software development service provider and therefore unsuitable as comparables.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
