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...
Rectification u/s 254 - One of the reasoning given by the Tribunal to uphold the cancellation order was that, assessee had suppressed vital and material facts regarding acquisition of shares of AJL and the purpose for which it was acquired at the time of seeking the registration. Thus, there is no substance in this contention that, merely because later on this fact was mentioned in the notes to the account of the balance-sheet filed subsequently along with the return of income amounts to furnishing of information at the time of registration. Accordingly, such contention raised in miscellaneous application is rejected. - AT
Rectification u/s 254 - One of the reasoning given by the Tribunal to uphold the cancellation order was that, assessee had suppressed vital and material facts regarding acquisition of shares of AJL and the purpose for which it was acquired at the time of seeking the registration. Thus, there is no substance in this contention that, merely because later on this fact was mentioned in the notes to the account of the balance-sheet filed subsequently along with the return of income amounts to furnishing of information at the time of registration. Accordingly, such contention raised in miscellaneous application is rejected. - AT
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