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...
Levy of penalty u/s 271D/E – Violation of provisions of section 269SS - 'journal entries' are outside the scope of the relevant penal provisions - completing the “empty formalities“ of payments and repayments by issuing/receiving cheque to swap/squire up the transactions, is not the intention of the provisions of section 269SS - AT
Levy of penalty u/s 271D/E – Violation of provisions of section 269SS - 'journal entries' are outside the scope of the relevant penal provisions - completing the “empty formalities“ of payments and repayments by issuing/receiving cheque to swap/squire up the transactions, is not the intention of the provisions of section 269SS - AT
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