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...
Expansion of scrutiny from the ‘Limited Scrutiny’ to ‘Complete Scrutiny - Addition u/s 68 - Since the CBDT Circular issued u/s. 119 of the Act is binding on the department/AO, the AO was bound by it and without taking approval in writing from Pr CIT/CIT could not have enquired into other issues other than the issue for which the assessment was selected for Limited Scrutiny.
Expansion of scrutiny from the ‘Limited Scrutiny’ to ‘Complete Scrutiny - Addition u/s 68 - Since the CBDT Circular issued u/s. 119 of the Act is binding on the department/AO, the AO was bound by it and without taking approval in writing from Pr CIT/CIT could not have enquired into other issues other than the issue for which the assessment was selected for Limited Scrutiny.
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