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...
Classification of services - adjudicating authority held the assessee have not been engaged in the activity of Site Formation and Clearances, Excavation and Earth moving service but only supplying earth moving machines like excavators etc. on rental basis and the physical control and possession of these machines have always remained with the clients who hired such machines - the department has not adduced any evidence to controvert the finding - demand quashed
Classification of services - adjudicating authority held the assessee have not been engaged in the activity of Site Formation and Clearances, Excavation and Earth moving service but only supplying earth moving machines like excavators etc. on rental basis and the physical control and possession of these machines have always remained with the clients who hired such machines - the department has not adduced any evidence to controvert the finding - demand quashed
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