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...
Penalty u/s 271A - failure to maintain the books of accounts u/s 44AA - when the very basis of levying the penalty by the ACIT is contrary to the assessment framed by the AO and even business income of the assessee prior to the assessment order was not above the limit prescribed u/s 44AA(2)(i) for keeping and maintaining the books of accounts then the case falls in the ambit of reasonable cause for the said failure - No penalty - AT
Penalty u/s 271A - failure to maintain the books of accounts u/s 44AA - when the very basis of levying the penalty by the ACIT is contrary to the assessment framed by the AO and even business income of the assessee prior to the assessment order was not above the limit prescribed u/s 44AA(2)(i) for keeping and maintaining the books of accounts then the case falls in the ambit of reasonable cause for the said failure - No penalty - AT
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