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...
Revision u/s 263 - AO considered the FMV at ₹ 300 per sq.ft. as on 1.4.1981 as submitted by the assessee without bringing any comparable cases or referring the matter to the DVO for valuation. This itself is an error committed by the AO that aspect involves the rejection of tax, which is prejudicial to the interests of the revenue. - AT
Revision u/s 263 - AO considered the FMV at ₹ 300 per sq.ft. as on 1.4.1981 as submitted by the assessee without bringing any comparable cases or referring the matter to the DVO for valuation. This itself is an error committed by the AO that aspect involves the rejection of tax, which is prejudicial to the interests of the revenue. - AT
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