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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Revision u/s 263 - reopening of assessment u/s 147 - period of limitation - these issues are not such which can render the assessment erroneous. Similarly what prejudice is caused to the revenue is also not clear from the order of the ld PCIT. In order to revise the order the twin conditions have to be satisfied i.e. the order has to be erroneous and secondly it must be prejudicial to the interest of the revenue. - AT
Revision u/s 263 - reopening of assessment u/s 147 - period of limitation - these issues are not such which can render the assessment erroneous. Similarly what prejudice is caused to the revenue is also not clear from the order of the ld PCIT. In order to revise the order the twin conditions have to be satisfied i.e. the order has to be erroneous and secondly it must be prejudicial to the interest of the revenue. - AT
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