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...
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Reopening of assessment u/s 147 - doubtful transactions of foreign remittances - The writ applicant in its own way has tried to explain while putting forward its objections, however, we do not find any meaningful discussion in the order disposing of the objections. In fact, none of the objections raised by the writ applicant could be said to have been taken into consideration by the Assessing Officer in a meaningful manner. - Matter restored before the AO - HC
Reopening of assessment u/s 147 - doubtful transactions of foreign remittances - The writ applicant in its own way has tried to explain while putting forward its objections, however, we do not find any meaningful discussion in the order disposing of the objections. In fact, none of the objections raised by the writ applicant could be said to have been taken into consideration by the Assessing Officer in a meaningful manner. - Matter restored before the AO - HC
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