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...
Alteration of charge - main charges for the offence u/s 276(C)(1) in connection with the very same Assessment Year for non payment of Tax - As stated supra, the Assessment Year is one and the same. Initial charge is for evasion of tax. Now, by way of alteration of charge, it is included to add evasion of payment of tax and hence, we do not find any error in the order passed by the Special Sessions Judge, in allowing the application. - HC
Alteration of charge - main charges for the offence u/s 276(C)(1) in connection with the very same Assessment Year for non payment of Tax - As stated supra, the Assessment Year is one and the same. Initial charge is for evasion of tax. Now, by way of alteration of charge, it is included to add evasion of payment of tax and hence, we do not find any error in the order passed by the Special Sessions Judge, in allowing the application. - HC
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TaxTMI 
TaxTMI 
of 4918 
