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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Reference the matter to the larger bench of 3 members by the Single Member Bench - Even if the learned Member hearing this appeal found it difficult to accept the view taken by the Division Benches of the Tribunal, then too the matter could have been placed only before two Members of the Tribunal, who could then have examined whether the matter require re-consideration by a Larger Bench of three Members of the Tribunal. - AT
Reference the matter to the larger bench of 3 members by the Single Member Bench - Even if the learned Member hearing this appeal found it difficult to accept the view taken by the Division Benches of the Tribunal, then too the matter could have been placed only before two Members of the Tribunal, who could then have examined whether the matter require re-consideration by a Larger Bench of three Members of the Tribunal. - AT
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