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...
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Revision u/s 263 - Receipts against sale of plots - Mismatch between the amount disclosed by the assessee and amount shown as per 26AS - Method of accounting - When all the receipts are duly reflected in the subsequent A.Ys by following the percentage completion method. The view of the AO is a plausible view and merely because the PCIT holds a different view, then that of the AO this cannot be a ground to cancel the order of the AO being erroneous and prejudicial to the interest of Revenue. - AT
Revision u/s 263 - Receipts against sale of plots - Mismatch between the amount disclosed by the assessee and amount shown as per 26AS - Method of accounting - When all the receipts are duly reflected in the subsequent A.Ys by following the percentage completion method. The view of the AO is a plausible view and merely because the PCIT holds a different view, then that of the AO this cannot be a ground to cancel the order of the AO being erroneous and prejudicial to the interest of Revenue. - AT
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