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...
Refund claim - effect of name change - defective return u/s 139(9) or not - in whose name the refund should be issued? - PAN database correction would certainly indicate what was the original name and therefore, Petitioner’s name when it filed the return of income tax was the correct name as it then existed. Therefore, there can never be a defect and notice issued u/s 139(9) was not a valid notice. If AO had checked the database, he would have found answer and could have avoided issuing a notice. - HC
Refund claim - effect of name change - defective return u/s 139(9) or not - in whose name the refund should be issued? - PAN database correction would certainly indicate what was the original name and therefore, Petitioner’s name when it filed the return of income tax was the correct name as it then existed. Therefore, there can never be a defect and notice issued u/s 139(9) was not a valid notice. If AO had checked the database, he would have found answer and could have avoided issuing a notice. - HC
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
