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...
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Reopening of assessment u/s 147 - merely because the AO finds the proof submitted by the assessee at the time of assessment proceedings to be not sufficient for the purpose of admitting the claim - it cannot be said that there was any failure on the part of the assessee so as to invoke the provisions of section 147 - HC
Reopening of assessment u/s 147 - merely because the AO finds the proof submitted by the assessee at the time of assessment proceedings to be not sufficient for the purpose of admitting the claim - it cannot be said that there was any failure on the part of the assessee so as to invoke the provisions of section 147 - HC
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