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...
Rejection of condonation of delay – Delay of 2005 days – The fact that despite instructions of the Commissioner, the appeal was not filed came to the light of the department only when tax appeal of the same assessee for other year came up for hearing - delay condoned - HC
Rejection of condonation of delay – Delay of 2005 days – The fact that despite instructions of the Commissioner, the appeal was not filed came to the light of the department only when tax appeal of the same assessee for other year came up for hearing - delay condoned - HC
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