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...
Penalty proceedings u/s 271(1)(c) - The assessee herein is a technical person and may not necessarily know the complicated tax laws - assessee acting on legal advice, readily came forward and offered the capital gains without resorting to litigation - onus of bonafide is broadly discharged - No penalty.
Penalty proceedings u/s 271(1)(c) - The assessee herein is a technical person and may not necessarily know the complicated tax laws - assessee acting on legal advice, readily came forward and offered the capital gains without resorting to litigation - onus of bonafide is broadly discharged - No penalty.
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