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...
Reopening of assessment u/s 147 - wrong facts in reasons recorded - AO completely ignored the fact that the return was already filed on 18.01.2010 and vide letter dated 24.02.2012 the assessee has explained that he is a regular assessee and produced the copy of Income-tax return filed - assumption of jurisdiction by the AO is bad in law
Reopening of assessment u/s 147 - wrong facts in reasons recorded - AO completely ignored the fact that the return was already filed on 18.01.2010 and vide letter dated 24.02.2012 the assessee has explained that he is a regular assessee and produced the copy of Income-tax return filed - assumption of jurisdiction by the AO is bad in law
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