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...
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Validity of reopening of assessment u/s 147 - reasons for reopening supplied but were not legible and not readable - Assessee was unable to file proper reply- It is not in dispute before me that the reasons said to have been supplied by the Revenue are neither legible nor readable. In the circumstances the reasons said to have been furnished are as good as no reasons furnished at all. - the reassessment order is quashed as bad in law - AT
Validity of reopening of assessment u/s 147 - reasons for reopening supplied but were not legible and not readable - Assessee was unable to file proper reply- It is not in dispute before me that the reasons said to have been supplied by the Revenue are neither legible nor readable. In the circumstances the reasons said to have been furnished are as good as no reasons furnished at all. - the reassessment order is quashed as bad in law - AT
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