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...
Additions towards Difference in receipts/sales which the assessee has agreed - If assessee has agreed for the difference, then there is no reason for the assessee to file this appeal unless assessee proves that acceptance was on account of coercion, threat, undue influence. In this case, the assessee has not alleged that there was any coercion, threat, undue influence. In these facts and circumstances of the case, this ground of the assessee is dismissed. - AT
Additions towards Difference in receipts/sales which the assessee has agreed - If assessee has agreed for the difference, then there is no reason for the assessee to file this appeal unless assessee proves that acceptance was on account of coercion, threat, undue influence. In this case, the assessee has not alleged that there was any coercion, threat, undue influence. In these facts and circumstances of the case, this ground of the assessee is dismissed. - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4921 
