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...
Unexplained investment u/s. 69 - DDIT (Inv.) could not have referred the question of cost of construction/valuation of the assessee’s building to the Valuation Officer in the year 2014 ; and thereafter, since the DVO did not present the valuation report after AO has referred the valuation vide letter dated 22.01.2016 as well as the Ld. CIT(A) within six months from the end of the month of the reference, the Ld. CIT(A) rightly held that DVO was bound by law [sec. 142A(6)] to have submitted the valuation report within the statutory time limit, which view we endorse.- AT
Unexplained investment u/s. 69 - DDIT (Inv.) could not have referred the question of cost of construction/valuation of the assessee’s building to the Valuation Officer in the year 2014 ; and thereafter, since the DVO did not present the valuation report after AO has referred the valuation vide letter dated 22.01.2016 as well as the Ld. CIT(A) within six months from the end of the month of the reference, the Ld. CIT(A) rightly held that DVO was bound by law [sec. 142A(6)] to have submitted the valuation report within the statutory time limit, which view we endorse.- AT
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