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...
Maintainability of appeal - time limitation - No doubt there was no application seeking Condonation of delay was filed by the appellant as has been acknowledged by ld. Counsel as on date as well - The delay is so minuscule that the malafide intent cannot be opined against the appellant. Law is otherwise settled that the disposal of a lis shall always be on merits. Law of limitation is otherwise to be exercised liberally. - It is deemed to be a fit case where Commissioner (Appeals) should have decided the appeal on merits after liberally exercising his discretion of condoning the delay - AT
Maintainability of appeal - time limitation - No doubt there was no application seeking Condonation of delay was filed by the appellant as has been acknowledged by ld. Counsel as on date as well - The delay is so minuscule that the malafide intent cannot be opined against the appellant. Law is otherwise settled that the disposal of a lis shall always be on merits. Law of limitation is otherwise to be exercised liberally. - It is deemed to be a fit case where Commissioner (Appeals) should have decided the appeal on merits after liberally exercising his discretion of condoning the delay - AT
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TaxTMI 
TaxTMI 
of 4918 
