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...
Belated filing of Form 10E did not, by itself, defeat the assessee's claim for tax relief where entitlement was otherwise admissible in law. The Tribunal applied a liberal construction to the filing requirement, treating the delay as a procedural lapse that should not override substantive rights. It held that the claim had to be examined and verified by the AO/CPC once the form was on record. The impugned order was set aside and the matter remanded for verification of Form 10E and grant of relief if found admissible.
Belated filing of Form 10E did not, by itself, defeat the assessee's claim for tax relief where entitlement was otherwise admissible in law. The Tribunal applied a liberal construction to the filing requirement, treating the delay as a procedural lapse that should not override substantive rights. It held that the claim had to be examined and verified by the AO/CPC once the form was on record. The impugned order was set aside and the matter remanded for verification of Form 10E and grant of relief if found admissible.
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