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...
Time Limitation - appeal stands filed after the normal period of three months provided for filing an appeal as also even after the extended period of three months for which the Commissioner (Appeals) is empowered to condone the delay - the time period of filing appeal has to be reckoned from the date of rejection of ROM Application.
Time Limitation - appeal stands filed after the normal period of three months provided for filing an appeal as also even after the extended period of three months for which the Commissioner (Appeals) is empowered to condone the delay - the time period of filing appeal has to be reckoned from the date of rejection of ROM Application.
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