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...
Unexplained purchase u/s 69C - alleged that purchase is not genuine and made from bogus biller/ accommodation entry provider - factual finding that no independent material to come to the conclusion that the purchases made by the assessee of gold and silver were either non genuine or that the same were made out of assessee’s known source and purchases were made through banking channel - no question of law arises
Unexplained purchase u/s 69C - alleged that purchase is not genuine and made from bogus biller/ accommodation entry provider - factual finding that no independent material to come to the conclusion that the purchases made by the assessee of gold and silver were either non genuine or that the same were made out of assessee’s known source and purchases were made through banking channel - no question of law arises
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