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...
Condonation of delay of 302 days in filing appeal - It is undisputed that it places a limitation on the extent to which the delay can be condoned by the Commissioner (Appeals). He cannot condone delay of more than one month. There is no provision in this Section for either Tribunal or any other authority to condone the delay in filing appeal before Commissioner (Appeals) in excess of one month. - AT
Condonation of delay of 302 days in filing appeal - It is undisputed that it places a limitation on the extent to which the delay can be condoned by the Commissioner (Appeals). He cannot condone delay of more than one month. There is no provision in this Section for either Tribunal or any other authority to condone the delay in filing appeal before Commissioner (Appeals) in excess of one month. - AT
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TaxTMI 
TaxTMI 
of 4918 
