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...
Seeking extension of stay already granted - the assessee is entitled for stay of demand even though it exceeds the period beyond the 365 days and we have already stated that the delay in non-disposal of the appeal is not attributable to the assessee. we are inclined to grant extension of stay in the instant case for a further period of 180 days or till the disposal of the appeal for this AY, whichever is earlier - AT
Seeking extension of stay already granted - the assessee is entitled for stay of demand even though it exceeds the period beyond the 365 days and we have already stated that the delay in non-disposal of the appeal is not attributable to the assessee. we are inclined to grant extension of stay in the instant case for a further period of 180 days or till the disposal of the appeal for this AY, whichever is earlier - AT
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