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 - Sure, the AO having not considered this aspect of the matter at all, there was no occasion for the assessee to clarify anything thereto, much less qua the date of transfer, which forms the fulcrum of his case/s. It does not, however, lie in the mouth of the assessee, who “explained” the source of the investment in property purchased during the year, to contend that the date of the said purchase falls in the immediately preceding year i.e., in the facts and circumstances of the case and the law in the matter. - Revision proceedings sustained - AT
Revision u/s 263 - Sure, the AO having not considered this aspect of the matter at all, there was no occasion for the assessee to clarify anything thereto, much less qua the date of transfer, which forms the fulcrum of his case/s. It does not, however, lie in the mouth of the assessee, who “explained” the source of the investment in property purchased during the year, to contend that the date of the said purchase falls in the immediately preceding year i.e., in the facts and circumstances of the case and the law in the matter. - Revision proceedings sustained - AT
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TaxTMI 
TaxTMI 
of 4918 
