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...
Penalty u/s 271C - assessee did not deducted income tax at source u/s. 194IA @ 1% on payments made for transfer of immovable property(other than agricultural land) - There is a latin maxim “ignorantia legis neminem excusat” which means that ignorance of law shall not excuse a person. But at the same time there is no presumption in law that all persons know all the laws, and more so complex fiscal laws concerning taxing statutes. - ssessee has demonstrated a reasonable cause u/s 273B - No penalty - AT
Penalty u/s 271C - assessee did not deducted income tax at source u/s. 194IA @ 1% on payments made for transfer of immovable property(other than agricultural land) - There is a latin maxim “ignorantia legis neminem excusat” which means that ignorance of law shall not excuse a person. But at the same time there is no presumption in law that all persons know all the laws, and more so complex fiscal laws concerning taxing statutes. - ssessee has demonstrated a reasonable cause u/s 273B - No penalty - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
