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...
Disallowance of commission - assessee cannot keep track of the person with whom she had done transactions - AO in the remand report confirms that the address given by the assessee is same on which payee obtained in his PAN card and filed his return of income - even the genuineness of the transactions is proved by the fact an MOU was entered and that in each of the bills/invoices raised, the details of services rendered - no disallowance
Disallowance of commission - assessee cannot keep track of the person with whom she had done transactions - AO in the remand report confirms that the address given by the assessee is same on which payee obtained in his PAN card and filed his return of income - even the genuineness of the transactions is proved by the fact an MOU was entered and that in each of the bills/invoices raised, the details of services rendered - no disallowance
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