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...
Proceedings u/s 153A - addition of Unexplained cash credit U/s 68 - if there is no incriminating material to reassess the income of the assessee then the AO legally cannot make the addition based on the information and evidence received from the Inv.Wing - it is open to the AO to initiate the proceeding U/s 147/148 instead of making the addition in the proceeding U/s 153A
Proceedings u/s 153A - addition of Unexplained cash credit U/s 68 - if there is no incriminating material to reassess the income of the assessee then the AO legally cannot make the addition based on the information and evidence received from the Inv.Wing - it is open to the AO to initiate the proceeding U/s 147/148 instead of making the addition in the proceeding U/s 153A
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4921 
