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...
Penalty imposed u/s 271AAA - in the penultimate paragraph of the assessment order the Assessing Officer has initiated proceedings for imposition of penalty under section 271AAA - contention of the learned Authorised Representative that no separate penalty proceeding has been initiated against certain additions is without any basis.
Penalty imposed u/s 271AAA - in the penultimate paragraph of the assessment order the Assessing Officer has initiated proceedings for imposition of penalty under section 271AAA - contention of the learned Authorised Representative that no separate penalty proceeding has been initiated against certain additions is without any basis.
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