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    October 21, 2026   Case Laws Income Tax
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    October 21, 2026   Case Laws Income Tax
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    October 21, 2026   Case Laws Income Tax
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    October 21, 2026   Case Laws Income Tax
    Notice under section 143(2) is mandatory for section 153C assessments, and its complete absence invalidates assessments.
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October 21, 2026   Case Laws Income Tax
Year-specific reassessment information cannot justify reopening when the underlying land-sale transaction belongs to the succeeding assessment year.
October 21, 2026   Case Laws Income Tax
Income Declaration Scheme eligibility may depend on verifying timely cheque tender and subsequent departmental credit under the applicable circular.
October 21, 2026   Case Laws Income Tax
Sufficient Cause for Delay Requires a Pleaded Explanation; Unexplained Inaction Leaves Revenue Appeal Time-Barred Under Limitation Law
October 21, 2026   Case Laws Income Tax
Angadia cash-transit receipts are taxable only to the extent of embedded commission, rather than as unexplained principal funds.
October 21, 2026   Case Laws Income Tax
Reassessment on Borrowed Satisfaction Fails When Recorded Share Transactions Were Already Examined and Accepted in Scrutiny
October 21, 2026   Case Laws Income Tax
Leasehold land rights under Section 56(2)(x): purchase excluded from income-tax additions on the facts presented.
October 21, 2026   Case Laws Income Tax
Revision jurisdiction cannot create a fresh foundation for independent cash-transaction penalty proceedings after a completed assessment.
October 21, 2026   Case Laws Income Tax
Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier assessment years.
October 21, 2026   Case Laws Income Tax
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available.
October 21, 2026   Case Laws Income Tax
Final assessment limitation follows DRP-specific timelines when the draft order is timely, despite expiry of general assessment limits.
October 21, 2026   Case Laws Income Tax
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unestablished.
October 21, 2026   Case Laws Income Tax
Accommodation-entry loan additions require evidence beyond generic third-party allegations, while interest disallowance needs proof of actual incurrence.
October 21, 2026   Case Laws Income Tax
Comparable uncontrolled price method requires actual uncontrolled transactions, resulting in deletion of unsupported related-party loan interest adjustment.
October 21, 2026   Case Laws Income Tax
Limitation for section 271D penalties requires a timely order, making orders beyond the statutory period invalid.
October 21, 2026   Case Laws Income Tax
Service of reassessment notice remains a jurisdictional precondition; participation after inquiry notice cannot cure non-service.
October 21, 2026   Case Laws Income Tax
Reassessment based on third-party information upheld, while profit element in fictitious purchases remains subject to estimated disallowance.
October 21, 2026   Case Laws Income Tax
Notice under section 143(2) is mandatory for section 153C assessments, and its complete absence invalidates assessments.
October 21, 2026   Case Laws Income Tax
Search assessment jurisdiction requires a valid assessment block, asset-linked escaped income, incriminating material, and timely completion.
October 21, 2026   Case Laws Income Tax
Royalty benchmarking requires reliable uncontrolled comparables, supporting TNMM aggregation where technical know-how payments are tied to manufacturing operations.
October 21, 2026   Case Laws Income Tax
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and transfer-pricing principles.

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Income Tax

TP Adjustment - applicability of Section 144C(13) - As provided...

Assessing Officer's Order Invalid for Not Following DRP Directions on ALP Adjustment u/s 144C(13) of Income Tax Act.

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Income Tax January 6, 2021 Case Laws AT
TP Adjustment - applicability of Section 144C(13) - As provided in the Section 144C(13) of the Act, the final order of the Assessing Officer should be in conformity with the directions given by the DRP. In the present case, while working out the ALP adjustment, he has not followed the direction of the DRP, consequently, the assessment order is bad in law - AT
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