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...
Appeal before the CIT(A) against the draft order - It is only the appeal filed by the assessee against the order u/s 144C(3) passed by the AO on 23.01.2020 that an effective and legally tenable appeal would call for decision. In our considered opinion, the ld. CIT(A) took an unimpeachable view in treating the appeal against the draft order as ‘defective’ and thus ‘not maintainable’.- AT
Appeal before the CIT(A) against the draft order - It is only the appeal filed by the assessee against the order u/s 144C(3) passed by the AO on 23.01.2020 that an effective and legally tenable appeal would call for decision. In our considered opinion, the ld. CIT(A) took an unimpeachable view in treating the appeal against the draft order as ‘defective’ and thus ‘not maintainable’.- AT
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TaxTMI 
TaxTMI 
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