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...
Revision u/s 263 - This is also not a case where the Commissioner failed to undertake inquiry in the course of the exercise of revisional jurisdiction. It is only in pursuance to such inquiry that the Commissioner recorded a categorical finding that the assessee had not even claimed any fees in respect of any alleged technical or management services rendered by it. This is not a case of some plausible view but this is a case where the decision was a result of non-application of mind to the materials on record. - ITAT was not justified in interfering with the CIT's order - HC
Revision u/s 263 - This is also not a case where the Commissioner failed to undertake inquiry in the course of the exercise of revisional jurisdiction. It is only in pursuance to such inquiry that the Commissioner recorded a categorical finding that the assessee had not even claimed any fees in respect of any alleged technical or management services rendered by it. This is not a case of some plausible view but this is a case where the decision was a result of non-application of mind to the materials on record. - ITAT was not justified in interfering with the CIT's order - HC
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