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...
Power of First Appellate Authority to change the character of the transaction - the correct interpretation to be given to clause (b) of Section 52(3) is to mean that the power is exercisable in the case of any other order which can be confirmed, canceled or varied, provided it does not change the character of the transaction nor the subject matter which was the issue before the Assessing Officer. - HC
Power of First Appellate Authority to change the character of the transaction - the correct interpretation to be given to clause (b) of Section 52(3) is to mean that the power is exercisable in the case of any other order which can be confirmed, canceled or varied, provided it does not change the character of the transaction nor the subject matter which was the issue before the Assessing Officer. - HC
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