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...
Revision u/s 263 - Deemed dividend addition u/s 2(22)(e) - Actual liability of the company has been transferred to the assessee which increases his liability and there is no revenue loss to the department. - Though the AO did not examine this issue, the assessment cannot be held to be prejudicial to the interest of the revenue.
Revision u/s 263 - Deemed dividend addition u/s 2(22)(e) - Actual liability of the company has been transferred to the assessee which increases his liability and there is no revenue loss to the department. - Though the AO did not examine this issue, the assessment cannot be held to be prejudicial to the interest of the revenue.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
