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...
Penalty u/s 271E - violation of the provision of section 269T - assessee has repaid the loans and advances received from various creditors otherwise than by crossed cheque - sufficient and reasonable cause for repayment of the loan to the directors and shareholders - the assessee has demonstrated that transactions were genuine with relevant documents. It is a mere technical violation and there is no loss to the revenue - No penalty - AT
Penalty u/s 271E - violation of the provision of section 269T - assessee has repaid the loans and advances received from various creditors otherwise than by crossed cheque - sufficient and reasonable cause for repayment of the loan to the directors and shareholders - the assessee has demonstrated that transactions were genuine with relevant documents. It is a mere technical violation and there is no loss to the revenue - No penalty - AT
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