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...
Reopening of assessment u/s 147 - unexplained properties purchased - AO was certainly satisfied with all the details provided by petitioner. If he was not, in other words, if petitioner had not furnished copy of the statement of bank accounts from which the payment was made as mentioned in the notice certainly the AO would not have passed the Assessment Order the way he had passed. - SCN issued u/s 148A(b) quashed - HC
Reopening of assessment u/s 147 - unexplained properties purchased - AO was certainly satisfied with all the details provided by petitioner. If he was not, in other words, if petitioner had not furnished copy of the statement of bank accounts from which the payment was made as mentioned in the notice certainly the AO would not have passed the Assessment Order the way he had passed. - SCN issued u/s 148A(b) quashed - HC
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