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...
Validity of assessment u/s 153C - it is necessary that the satisfaction must be recorded by the AO of the searched person and thereafter the documents are to be handed over to the AO of other person and this position will not alter even if the AO for the searched person and the other person i.e. the assessee is the same - AT
Validity of assessment u/s 153C - it is necessary that the satisfaction must be recorded by the AO of the searched person and thereafter the documents are to be handed over to the AO of other person and this position will not alter even if the AO for the searched person and the other person i.e. the assessee is the same - AT
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