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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Condonation of delay of 27 months - factory premises was under attachment by the Excise department - Neither the AO has acted in a fair manner nor the assessee has prosecuted its income tax proceedings before the ld.Revenue authorities diligently - If something has been done illegally against it, then that illegality should not be regularized on account of technicalities - condoned the delay subject to cost of ₹ 50,000/-.
Condonation of delay of 27 months - factory premises was under attachment by the Excise department - Neither the AO has acted in a fair manner nor the assessee has prosecuted its income tax proceedings before the ld.Revenue authorities diligently - If something has been done illegally against it, then that illegality should not be regularized on account of technicalities - condoned the delay subject to cost of ₹ 50,000/-.
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