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...
Penalty levied u/s. 272A (1)(c) - non compliance with summons issued under section 131(1A) - ignorance of law is certainly no excuse for a default committed but, at the same time, there is no presumption in law that everybody knows the law - The application of this rule would differ from case to case and person to person. In a given case, there may be a person who is quite illiterate, living in remote village, rarely coming in touch with law enforcing machinery and not required to discharge any statutory obligations under a particular law. Ignorance of law may be a good excuse in his case. - No penalty - AT
Penalty levied u/s. 272A (1)(c) - non compliance with summons issued under section 131(1A) - ignorance of law is certainly no excuse for a default committed but, at the same time, there is no presumption in law that everybody knows the law - The application of this rule would differ from case to case and person to person. In a given case, there may be a person who is quite illiterate, living in remote village, rarely coming in touch with law enforcing machinery and not required to discharge any statutory obligations under a particular law. Ignorance of law may be a good excuse in his case. - No penalty - AT
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TaxTMI 
TaxTMI 
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