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...
Penalty under section 221(1) read with section 140A(3) - default in payment of the tax demand - penalty @ 5% of the admitted tax liability would be reasonable and meet the ends of justice - AT
Penalty under section 221(1) read with section 140A(3) - default in payment of the tax demand - penalty @ 5% of the admitted tax liability would be reasonable and meet the ends of justice - AT
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