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 - ITAT refused to admit additional ground - Having found that the recording of satisfaction by the AO of the searched person is mandatory; which is the question of law, what remained was only to call for the records of the assessment proceedings of the appellant and peruse the same to find out the satisfaction recorded before transmitting the files to the AO of the appellant. We are hence satisfied that the ground necessarily has to be admitted and the Tribunal committed a mistake in refusing the admission of such ground. - HC
Rectification u/s 254 - ITAT refused to admit additional ground - Having found that the recording of satisfaction by the AO of the searched person is mandatory; which is the question of law, what remained was only to call for the records of the assessment proceedings of the appellant and peruse the same to find out the satisfaction recorded before transmitting the files to the AO of the appellant. We are hence satisfied that the ground necessarily has to be admitted and the Tribunal committed a mistake in refusing the admission of such ground. - HC
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