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...
Validity of Orders passed u/s 201(1) and 201(1A) - period of limitation - retrospective applicability of the provisions - TDS u/s 192 - non deduction of TDS on Cash medical benefit to employees - “assessee in default" - Such orders having been passed after expiry of two years from the financial year wherein TDS statements were filed by the assessee under section 200 of the Act, is therefore barred by limitation, hence, has to be declared as null and void. - AT
Validity of Orders passed u/s 201(1) and 201(1A) - period of limitation - retrospective applicability of the provisions - TDS u/s 192 - non deduction of TDS on Cash medical benefit to employees - “assessee in default" - Such orders having been passed after expiry of two years from the financial year wherein TDS statements were filed by the assessee under section 200 of the Act, is therefore barred by limitation, hence, has to be declared as null and void. - AT
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