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...
Revision u/s 263 - issue of fresh share in lieu of investment in shares - once, the AO has found that a transaction is not in terms of any money after the detailed inquiry and getting the entire records from these 15 companies, then how the CIT had reached to a conclusion that the AO has failed to investigate the genuineness and creditworthiness of source - there was no lack of enquiry or non-application of mind by the AO
Revision u/s 263 - issue of fresh share in lieu of investment in shares - once, the AO has found that a transaction is not in terms of any money after the detailed inquiry and getting the entire records from these 15 companies, then how the CIT had reached to a conclusion that the AO has failed to investigate the genuineness and creditworthiness of source - there was no lack of enquiry or non-application of mind by the AO
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