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...
Addition u/s 69A - survey action under Section 133A - Addition based on loose paper in search - There is no concrete evidence which has been brought on record by the Assessing Officer to establish that the entry 'Parvez Sir' in the impounded paper establishes the fact that it refers to Respondent. The Assessing Officer has made the addition only on the surmise that the impounded papers were containing entries which are dated 15/11/2006 whereas Respondent retired from the firm on 14/11/2006. - HC
Addition u/s 69A - survey action under Section 133A - Addition based on loose paper in search - There is no concrete evidence which has been brought on record by the Assessing Officer to establish that the entry 'Parvez Sir' in the impounded paper establishes the fact that it refers to Respondent. The Assessing Officer has made the addition only on the surmise that the impounded papers were containing entries which are dated 15/11/2006 whereas Respondent retired from the firm on 14/11/2006. - HC
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TaxTMI 
TaxTMI 
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