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...
A typographical error in the appellate directions led the Assessing Officer to retain part of a section 69 addition for unexplained investment, even though the draft assessment order had made a combined addition for time deposits and reportable transactions. The Tribunal read the reasoning in the directions as showing that both underlying components were meant to be deleted, and treated the differing aggregate figure as a clerical mistake. On that basis, no balance addition could survive in the final assessment order, and the retained amount was deleted.
A typographical error in the appellate directions led the Assessing Officer to retain part of a section 69 addition for unexplained investment, even though the draft assessment order had made a combined addition for time deposits and reportable transactions. The Tribunal read the reasoning in the directions as showing that both underlying components were meant to be deleted, and treated the differing aggregate figure as a clerical mistake. On that basis, no balance addition could survive in the final assessment order, and the retained amount was deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
