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...
Reassessment u/s 147 - bogus purchases - When the investigation wing has received specific information from another gov. Dept. that assessee has indulged in hawala transaction by availing bogus purchases bills to inflate its purchases, it cannot be said that the AO had no information or that there was no fresh material for reopening of the assessment - reopening sustained
Reassessment u/s 147 - bogus purchases - When the investigation wing has received specific information from another gov. Dept. that assessee has indulged in hawala transaction by availing bogus purchases bills to inflate its purchases, it cannot be said that the AO had no information or that there was no fresh material for reopening of the assessment - reopening sustained
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