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...
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Orders passed by CIT-A without proper jurisdiction - the very action of then Ld. CIT(A)in ignoring the binding directions given by DGIT and proceeding to pass orders results serious lapse on his part in administering justice. We also notice that all the orders impugned in these appeals have been passed between 5.7.2018 and 13.7.2018, numbering around 50 orders, involving different Assessees and different issues, which is difficult task for any appellate authority. Hence we agree with the submission of Ld. Standing Counsel that the interests of revenue is prejudiced by the said action of the then Ld. CIT(A) - AT
Orders passed by CIT-A without proper jurisdiction - the very action of then Ld. CIT(A)in ignoring the binding directions given by DGIT and proceeding to pass orders results serious lapse on his part in administering justice. We also notice that all the orders impugned in these appeals have been passed between 5.7.2018 and 13.7.2018, numbering around 50 orders, involving different Assessees and different issues, which is difficult task for any appellate authority. Hence we agree with the submission of Ld. Standing Counsel that the interests of revenue is prejudiced by the said action of the then Ld. CIT(A) - AT
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