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 221 r.w.s. 140A - default of non-payment of taxes on due date - Provisions of Section 140A (3) can apply only when there is a self-assessment tax payable with respect to the return filed u/s 139 of the act. Further, if there is a failure u/s 140 A (3) then only assessee can be held to be “assessee in default”. As in the present case there is no return of income filed u/s 139 of the income tax act, therefore any penalty based on that return, does not survive. - AT
Penalty u/s 221 r.w.s. 140A - default of non-payment of taxes on due date - Provisions of Section 140A (3) can apply only when there is a self-assessment tax payable with respect to the return filed u/s 139 of the act. Further, if there is a failure u/s 140 A (3) then only assessee can be held to be “assessee in default”. As in the present case there is no return of income filed u/s 139 of the income tax act, therefore any penalty based on that return, does not survive. - AT
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TaxTMI 
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