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...
Condonation of delay of 6 months and 22 days in filing appeal - rejection on the ground of time limitation or not - The period till 30.9.2020/ 28.2.2022 still remains excluded, hence appeal filed on 25.09.2020 is held to have been filed within the period of limitation. Irrespective that the benefit of both these announcements have to be extended in favour of the appellant. The matter cannot be held to have crossed the period of its limitation as the same was extended. - AT
Condonation of delay of 6 months and 22 days in filing appeal - rejection on the ground of time limitation or not - The period till 30.9.2020/ 28.2.2022 still remains excluded, hence appeal filed on 25.09.2020 is held to have been filed within the period of limitation. Irrespective that the benefit of both these announcements have to be extended in favour of the appellant. The matter cannot be held to have crossed the period of its limitation as the same was extended. - AT
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TaxTMI 
TaxTMI 
of 4918 
