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...
Extended period of limitation - when the Department sought details of commission received by the appellant from the M/s ICICI HFC Ltd, the assessee failed to respond to the letter of the Department and even summons issued to them - this conduct amounts to willful and deliberate and withholding and of suppression facts - invocation of extended period is justified.
Extended period of limitation - when the Department sought details of commission received by the appellant from the M/s ICICI HFC Ltd, the assessee failed to respond to the letter of the Department and even summons issued to them - this conduct amounts to willful and deliberate and withholding and of suppression facts - invocation of extended period is justified.
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