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...
Penalty u/s 271AAB - relevant column of ‘approval letter No.’ and ‘Date’ had been left blank in the penalty order which have been filled with pen on receipt of said approval of JCIT vide letter no. 1036 dt. 30/09/2016 - it is crystal clear that the penalty order passed by the AO on 29/09/2016 was before taking the approval - penalty order is void ab-initio
Penalty u/s 271AAB - relevant column of ‘approval letter No.’ and ‘Date’ had been left blank in the penalty order which have been filled with pen on receipt of said approval of JCIT vide letter no. 1036 dt. 30/09/2016 - it is crystal clear that the penalty order passed by the AO on 29/09/2016 was before taking the approval - penalty order is void ab-initio
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