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...
Revision u/s 263 - applicability of provisions of section 56(2)(vii)(b)(ii) - purchase of shops on less than stamp valuation - record clearly reveal that the AO has completely failed to examine the applicability of section 56(2)(vii)(b)(ii) to the subject transactions - due to such failure assessment order not only erroneous but prejudicial to the interests of Revenue - revision upheld
Revision u/s 263 - applicability of provisions of section 56(2)(vii)(b)(ii) - purchase of shops on less than stamp valuation - record clearly reveal that the AO has completely failed to examine the applicability of section 56(2)(vii)(b)(ii) to the subject transactions - due to such failure assessment order not only erroneous but prejudicial to the interests of Revenue - revision upheld
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