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...
Revision u/s 263 by CIT - different interpretation of a decision of court relating to assessee - CIT has not brought on record any cogent & conclusive material which would prove or show that the course followed by the AO was unsustainable in law - AO followed one of the course permissible in law - revision order quashed
Revision u/s 263 by CIT - different interpretation of a decision of court relating to assessee - CIT has not brought on record any cogent & conclusive material which would prove or show that the course followed by the AO was unsustainable in law - AO followed one of the course permissible in law - revision order quashed
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