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...
Validity of initiation of proceedings u/s 147/148 - Addition u/s 69 - anonymous complaint - Once the sellers as well as the purchasers have denied the allegation of any unaccounted purchase consideration/sale consideration paid or received in their statements recorded under section 131 of the Act, then in the absence of any such fact detected during the investigation carried out by the DDIT, the opinion formed by the DDIT and consequently by the AO is merely based on the allegation made in the complaint which is anonymous complaint as admitted and stated by the DDIT Investigation - AT
Validity of initiation of proceedings u/s 147/148 - Addition u/s 69 - anonymous complaint - Once the sellers as well as the purchasers have denied the allegation of any unaccounted purchase consideration/sale consideration paid or received in their statements recorded under section 131 of the Act, then in the absence of any such fact detected during the investigation carried out by the DDIT, the opinion formed by the DDIT and consequently by the AO is merely based on the allegation made in the complaint which is anonymous complaint as admitted and stated by the DDIT Investigation - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
