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...
Reopening of assessment u/s 147 - upon reading the reasons to believe as a whole the ‘live link’ between the material in the form of the investigation report and the formation of belief that income that has escaped assessment is prima facie discernable - the Court hastens to add that this is a prima facie view which is all that is necessary at this stage - reassessment upheld
Reopening of assessment u/s 147 - upon reading the reasons to believe as a whole the ‘live link’ between the material in the form of the investigation report and the formation of belief that income that has escaped assessment is prima facie discernable - the Court hastens to add that this is a prima facie view which is all that is necessary at this stage - reassessment upheld
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