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...
Protective assessment/addition - No substantive assessment/addition in the hands of other assessee - It is therefore a case where no substantive additions have been made in hands of M/s Bhushan Power & Steel Ltd and at the same time, only protective assessment has been made in the hands of the assessee - Accordingly, the protective addition so made by the AO and confirmed by the ld CIT(A) is hereby directed to be deleted. The enhancement done by the ld CIT(A) by an amount under section 69C of the Act, the same being consequential in nature is also directed to be deleted. - AT
Protective assessment/addition - No substantive assessment/addition in the hands of other assessee - It is therefore a case where no substantive additions have been made in hands of M/s Bhushan Power & Steel Ltd and at the same time, only protective assessment has been made in the hands of the assessee - Accordingly, the protective addition so made by the AO and confirmed by the ld CIT(A) is hereby directed to be deleted. The enhancement done by the ld CIT(A) by an amount under section 69C of the Act, the same being consequential in nature is also directed to be deleted. - AT
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