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...
Assessment u/s 153C - Period of limitation - although the Assessing Officer of the searched person and the other person(the assessee) was the same, satisfaction was recorded by the Assessing Officer for invoking the provisions of section 153C of the Act on 21/12/2010, the said date would be deemed to be the date of receiving documents by the Assessing Officer. Thus, the year of search would be FY 2010-11 relevant to AY 2011-12. - AT
Assessment u/s 153C - Period of limitation - although the Assessing Officer of the searched person and the other person(the assessee) was the same, satisfaction was recorded by the Assessing Officer for invoking the provisions of section 153C of the Act on 21/12/2010, the said date would be deemed to be the date of receiving documents by the Assessing Officer. Thus, the year of search would be FY 2010-11 relevant to AY 2011-12. - AT
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