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...
Rectification u/s 154 - Transfer pricing adjustments - The assessee carried the matter on appeal to the Tribunal and once again, the assessee never raised any contention with regard to the validity of the notice dated 28.03.2006. Thus, considering this factual situation, we are of the clear view that the present attempt of the assessee is not tenable and accordingly rejected. - The assessment order dated 28.02.2006 is an order u/s 143(3) and not an order u/s 92C(3) of the Act. - The argument of the assessee before us is that the Assessing Officer has exercised jurisdiction u/s 92C(3) and the TPO parallely cannot exercise his power u/s92CA. On facts, the assessee is wrong. - HC
Rectification u/s 154 - Transfer pricing adjustments - The assessee carried the matter on appeal to the Tribunal and once again, the assessee never raised any contention with regard to the validity of the notice dated 28.03.2006. Thus, considering this factual situation, we are of the clear view that the present attempt of the assessee is not tenable and accordingly rejected. - The assessment order dated 28.02.2006 is an order u/s 143(3) and not an order u/s 92C(3) of the Act. - The argument of the assessee before us is that the Assessing Officer has exercised jurisdiction u/s 92C(3) and the TPO parallely cannot exercise his power u/s92CA. On facts, the assessee is wrong. - HC
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