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...
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Rectification of mistake u/s 254 - dismissal of Revenue’s appeal for low tax effect - Tribunal failed to note that para 10(c) of CBDT Circular which state that Revenue would contest appeals in respect of orders which were the result of the Department’s acceptance of Revenue audit objections, even if the tax effect in such appeal is lower than the prescribed limit - mistake apparent on record
Rectification of mistake u/s 254 - dismissal of Revenue’s appeal for low tax effect - Tribunal failed to note that para 10(c) of CBDT Circular which state that Revenue would contest appeals in respect of orders which were the result of the Department’s acceptance of Revenue audit objections, even if the tax effect in such appeal is lower than the prescribed limit - mistake apparent on record
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