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...
An AO must pass the final assessment order in conformity with the DRP's directions under section 144C(13); any departure, even if said to be due to mistake or misunderstanding, is impermissible. Applying binding High Court precedent, the Tribunal quashed the non-compliant final assessment order because the AO repeated the draft order and ignored the relief granted by the DRP. The transfer pricing and consequential grounds were left open as academic.
An AO must pass the final assessment order in conformity with the DRP's directions under section 144C(13); any departure, even if said to be due to mistake or misunderstanding, is impermissible. Applying binding High Court precedent, the Tribunal quashed the non-compliant final assessment order because the AO repeated the draft order and ignored the relief granted by the DRP. The transfer pricing and consequential grounds were left open as academic.
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