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...
Imposition of penalty - Misutilization of Form-C - Mere narration of wrong representation or utilisation of Form-C without a clear cut finding about the false representation did not fulfil the requirement of law. Though the assessee may not have been strictly entitled to use the declaration Form- C, that fact alone could not result in an automatic levy of penalty
Imposition of penalty - Misutilization of Form-C - Mere narration of wrong representation or utilisation of Form-C without a clear cut finding about the false representation did not fulfil the requirement of law. Though the assessee may not have been strictly entitled to use the declaration Form- C, that fact alone could not result in an automatic levy of penalty
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