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...
Revision u/s 263 - Unexplained cash deposits - Merely because documents, noted by the AO to be produced by the creditor of source of cash deposit in response to summons issued to him u/s. 131 were not found in the case records, that cannot be the reason for holding the assessment order to be in error for accepting the genuineness of the source of cash deposit. The fact of issuance of summons by the AO is not doubted or disputed by the Ld. PCIT. - Revision order set aside - AT
Revision u/s 263 - Unexplained cash deposits - Merely because documents, noted by the AO to be produced by the creditor of source of cash deposit in response to summons issued to him u/s. 131 were not found in the case records, that cannot be the reason for holding the assessment order to be in error for accepting the genuineness of the source of cash deposit. The fact of issuance of summons by the AO is not doubted or disputed by the Ld. PCIT. - Revision order set aside - AT
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TaxTMI 
TaxTMI 
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