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...
Validity of Settlement Commission order u/s 245D(4) - Proof of true and full disclosure of income - While this Court does not accept the contention of the petitioner regarding the Settlement Commission not being empowered to make assessment, it accepts the second submission of learned counsel for the petitioner that the Settlement Commission ought to have examined the matter after giving opportunity of hearing to the petitioner with regard to the true and correct disclosure - HC
Validity of Settlement Commission order u/s 245D(4) - Proof of true and full disclosure of income - While this Court does not accept the contention of the petitioner regarding the Settlement Commission not being empowered to make assessment, it accepts the second submission of learned counsel for the petitioner that the Settlement Commission ought to have examined the matter after giving opportunity of hearing to the petitioner with regard to the true and correct disclosure - HC
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