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 interest u/s 234D - mistake in computing the interest u/s 244A has been rectified by passing the order u/s 154 and with which the assessee has no quarrel. It is not the case of Revenue that the refund has arisen due to order u/s 143(1) - Therefore, the first necessary condition for charging of interest u/s 234D is not satisfied - AT
Levy of interest u/s 234D - mistake in computing the interest u/s 244A has been rectified by passing the order u/s 154 and with which the assessee has no quarrel. It is not the case of Revenue that the refund has arisen due to order u/s 143(1) - Therefore, the first necessary condition for charging of interest u/s 234D is not satisfied - AT
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