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...
Rectification u/s 254(2) - failure to take cognizance of certain judicial pronouncements - non-consideration of the judgments of the jurisdictional High Court and the Tribunal, which were specifically relied upon by the counsel during the course of the hearing of the appeal constitutes a mistake apparent from record - rectification allowable
Rectification u/s 254(2) - failure to take cognizance of certain judicial pronouncements - non-consideration of the judgments of the jurisdictional High Court and the Tribunal, which were specifically relied upon by the counsel during the course of the hearing of the appeal constitutes a mistake apparent from record - rectification allowable
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TaxTMI 
TaxTMI 
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