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 271F - not filing the return of income (ITR) - It is noteworthy to mention that the provisions of Section 273B categorically mentions that penalty u/s 271F is not leviable in case the assessee proves that there was a reasonable cause for not filing the return of income during the year under consideration, as per provisions of Section 139 of the Act. - AT
Penalty u/s 271F - not filing the return of income (ITR) - It is noteworthy to mention that the provisions of Section 273B categorically mentions that penalty u/s 271F is not leviable in case the assessee proves that there was a reasonable cause for not filing the return of income during the year under consideration, as per provisions of Section 139 of the Act. - AT
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