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...
Reassessment u/s 147 - precluding the Revenue from urging the merits of the issue only because it had not challenged the order of the CIT (A) annulling the re-assessment proceedings is not a mere ‘technical approach’ - there was no basis for the re-opening of the assessment except the presumptive observation of the Revenue audit which itself was not based on any tangible material - no substantial question of law arises
Reassessment u/s 147 - precluding the Revenue from urging the merits of the issue only because it had not challenged the order of the CIT (A) annulling the re-assessment proceedings is not a mere ‘technical approach’ - there was no basis for the re-opening of the assessment except the presumptive observation of the Revenue audit which itself was not based on any tangible material - no substantial question of law arises
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
