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...
Revision u/s 263 - Assessee company is a private limited company and it is closely held and has raised share subscription from its own directors and their wives who are all income tax assessee's and all the money has come through banking channel and their creditworthiness has also been proved by the documents produced - PCIT erred in finding that the source of share subscribers has not been properly enquired by the AO - Revision order quashed - AT
Revision u/s 263 - Assessee company is a private limited company and it is closely held and has raised share subscription from its own directors and their wives who are all income tax assessee's and all the money has come through banking channel and their creditworthiness has also been proved by the documents produced - PCIT erred in finding that the source of share subscribers has not been properly enquired by the AO - Revision order quashed - AT
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