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...
Levy of penalty upon the Director of appellant’s company and upon Head of Finance and Accounts of the appellants’ company and upon the company itself - The SCN is held time-barred. Findings of adjudicating authority are held unreasonable. Hence, the orders under challenge confirming demand with interest against company and imposing penalty on company, its director and its financial head are hereby set aside - AT
Levy of penalty upon the Director of appellant’s company and upon Head of Finance and Accounts of the appellants’ company and upon the company itself - The SCN is held time-barred. Findings of adjudicating authority are held unreasonable. Hence, the orders under challenge confirming demand with interest against company and imposing penalty on company, its director and its financial head are hereby set aside - AT
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TaxTMI 
TaxTMI 
of 4918 
