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...
Validity of faceless assessment - allegation of the petitioner that it did not have the opportunity of being heard by the assessing officer - Liberty granted to the petitioner herein to avail the remedy of filing a statutory appellate remedy. In the event, the petitioner avails such a remedy and is under an obligation to make a pre-deposit before the said authority, an application may be made seeking waiver or reduction in the deposit to be made, as the case may be. - SC
Validity of faceless assessment - allegation of the petitioner that it did not have the opportunity of being heard by the assessing officer - Liberty granted to the petitioner herein to avail the remedy of filing a statutory appellate remedy. In the event, the petitioner avails such a remedy and is under an obligation to make a pre-deposit before the said authority, an application may be made seeking waiver or reduction in the deposit to be made, as the case may be. - SC
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