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 assessment order passed u/s 153A r.w.s. 143(3) - Extension of period of limitation - reference made by the revenue to Swiss authorities - Since the reference is not a valid reference, the claim of the revenue that period of limitation is extended by one year under section 153B based on the reference is not tenable - AT
Validity of assessment order passed u/s 153A r.w.s. 143(3) - Extension of period of limitation - reference made by the revenue to Swiss authorities - Since the reference is not a valid reference, the claim of the revenue that period of limitation is extended by one year under section 153B based on the reference is not tenable - AT
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