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...
Revision u/s 263 - claim of deduction of expenditure and depreciation but no revenue has been earned - Pr.CIT has directed the AO to make further enquiry on the admissibility of expenditure - Except for an endeavour to embark upon a fishing & roving enquiry, there is no merit in the order passed by ld. Pr.CIT. In our considered opinion, the basic premise on which Pr.CIT has invoked his jurisdiction u/s 263 is legally not sustainable. - AT
Revision u/s 263 - claim of deduction of expenditure and depreciation but no revenue has been earned - Pr.CIT has directed the AO to make further enquiry on the admissibility of expenditure - Except for an endeavour to embark upon a fishing & roving enquiry, there is no merit in the order passed by ld. Pr.CIT. In our considered opinion, the basic premise on which Pr.CIT has invoked his jurisdiction u/s 263 is legally not sustainable. - AT
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TaxTMI 
TaxTMI 
of 4918 
