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 - reopening cannot be justified on any other material other than referred in the reasons recorded. - Mental exercise must be self-evident from the reasons recorded. Reasons must be self-speaking and self-defending. - AT
Reopening of assessment u/s 147 - reopening cannot be justified on any other material other than referred in the reasons recorded. - Mental exercise must be self-evident from the reasons recorded. Reasons must be self-speaking and self-defending. - AT
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