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...
Penalty u/s 271(1)(c) - there is no ‘tax sought to be evaded’, in terms of Explanation 4 to section 271(1)(c), on which penalty could be levied - even as the asessee has not furnished any explanation during the penalty proceedings or in the appellate proceedings no penalty is leviable
Penalty u/s 271(1)(c) - there is no ‘tax sought to be evaded’, in terms of Explanation 4 to section 271(1)(c), on which penalty could be levied - even as the asessee has not furnished any explanation during the penalty proceedings or in the appellate proceedings no penalty is leviable
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