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...
Enhancement of income by CIT(A) - Valuation of the shares as per Rule 11UA - Additions u/s 56(2)(viib) - Determination of Consideration received for such shares in exceeds the fair market value of the shares (FMV) - the CIT(A) have committed an error in rejected the valuation done by the assessee from prescribed expert as per the prescribed method, which ultimately resulted in enhancement of income of the Assessee u/s 251(1) of the Act - Additions deleted - AT
Enhancement of income by CIT(A) - Valuation of the shares as per Rule 11UA - Additions u/s 56(2)(viib) - Determination of Consideration received for such shares in exceeds the fair market value of the shares (FMV) - the CIT(A) have committed an error in rejected the valuation done by the assessee from prescribed expert as per the prescribed method, which ultimately resulted in enhancement of income of the Assessee u/s 251(1) of the Act - Additions deleted - AT
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