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...
Validity of order u/s 263 - Failure of the AO of examine the income - In the assessment order, there is no discussion about the above referred two incomes nor the assessee had filed any details before the PCIT. Even, before us in the present appeal, no paper-book has been filed and the assessee has not appeared on any of the given dates which shows that the assessee has no material evidence to rebut the findings of the PCIT. - AT
Validity of order u/s 263 - Failure of the AO of examine the income - In the assessment order, there is no discussion about the above referred two incomes nor the assessee had filed any details before the PCIT. Even, before us in the present appeal, no paper-book has been filed and the assessee has not appeared on any of the given dates which shows that the assessee has no material evidence to rebut the findings of the PCIT. - AT
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TaxTMI 
TaxTMI 
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