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...
Entitlement to exemption u/s 10(23C)(iv) r.w.s. 2(15) - assessee itself has entertained doubts about its exemption and filed a revised return, which itself shows that the assessee was not eligible for exemption - assessee is not entitled for exemption, therefore, the principle of consistency cannot be followed - AT
Entitlement to exemption u/s 10(23C)(iv) r.w.s. 2(15) - assessee itself has entertained doubts about its exemption and filed a revised return, which itself shows that the assessee was not eligible for exemption - assessee is not entitled for exemption, therefore, the principle of consistency cannot be followed - AT
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