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...
Special audit u/s 142(2A) - Period of limitation - reasons for change in accounting system - method of valuation of closing stock - AO does not point out a single complexity in the accounts of the assessee. - What is clearly evident is that the reference for special audit was merely made for obtaining certain explanation and information which were further required by the AO for the purposes of assessment of income of the assessee. In effect,the AO, was shifting his responsibility to the special auditor. This is surely not the purpose for which special audit can be referred to under law. - AT
Special audit u/s 142(2A) - Period of limitation - reasons for change in accounting system - method of valuation of closing stock - AO does not point out a single complexity in the accounts of the assessee. - What is clearly evident is that the reference for special audit was merely made for obtaining certain explanation and information which were further required by the AO for the purposes of assessment of income of the assessee. In effect,the AO, was shifting his responsibility to the special auditor. This is surely not the purpose for which special audit can be referred to under law. - AT
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TaxTMI 
TaxTMI 
of 4921 
