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) - assessee had not withheld any relevant information regarding the short term capital gains from the AO which was based on the valuation report of an architect which was partly accepted by the Ld. CIT (A) - there is no factual finding that the assessee had furnished any inaccurate particulars while bifurcating the value between land and buildings while computing STCG - no penalty
Penalty u/s 271(1)(c) - assessee had not withheld any relevant information regarding the short term capital gains from the AO which was based on the valuation report of an architect which was partly accepted by the Ld. CIT (A) - there is no factual finding that the assessee had furnished any inaccurate particulars while bifurcating the value between land and buildings while computing STCG - no penalty
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