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...
Rectification u/s 254 - non-consideration of decision of tribunal relied upon by the assessee on identical fact - decision subsequently approved by Hon’ble Bombay High Court and revenue’s SLP dismissed by Hon’ble Apex Court - non-consideration of binding judicial precedent of High Court would constitute mistake apparent from record
Rectification u/s 254 - non-consideration of decision of tribunal relied upon by the assessee on identical fact - decision subsequently approved by Hon’ble Bombay High Court and revenue’s SLP dismissed by Hon’ble Apex Court - non-consideration of binding judicial precedent of High Court would constitute mistake apparent from record
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