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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Revision u/s 263 - The Pr. CIT has not pointed out as to what is the error committed by the AO in accepting the replies from various parties. Without pointing out any defects, it cannot be said that there is an error which caused prejudice to the interest of the Revenue. This is not a case of lack of enquiry or non-application of mind. The AO has made an enquiry and has taken a plausible view on the issues. - AT
Revision u/s 263 - The Pr. CIT has not pointed out as to what is the error committed by the AO in accepting the replies from various parties. Without pointing out any defects, it cannot be said that there is an error which caused prejudice to the interest of the Revenue. This is not a case of lack of enquiry or non-application of mind. The AO has made an enquiry and has taken a plausible view on the issues. - AT
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