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...
Validity of reopening of assessment - claim for deductions under section 80HHC and 80IA - the order of the A.O. stood merged with the order of the CIT(A) and had no existence of it’s own, and, as such, assessment could not be reopened in respect of the said item. - AT
Validity of reopening of assessment - claim for deductions under section 80HHC and 80IA - the order of the A.O. stood merged with the order of the CIT(A) and had no existence of it’s own, and, as such, assessment could not be reopened in respect of the said item. - AT
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