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...
Penalty u/s 271(1)(c) - the fact that the assessee and his son have declared the undisclosed income in their individual return of income and have paid taxes but capital expenditure and payment towards purchase of land cannot be held as undisclosed income in the hands of the assessee - no penalty under explanation 5A to section 271(1)(c) unless assessee is owner of the undisclosed income
Penalty u/s 271(1)(c) - the fact that the assessee and his son have declared the undisclosed income in their individual return of income and have paid taxes but capital expenditure and payment towards purchase of land cannot be held as undisclosed income in the hands of the assessee - no penalty under explanation 5A to section 271(1)(c) unless assessee is owner of the undisclosed income
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