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...
Jurisdiction of the Income Tax authority to issue notice u/s 143[2] of the IT Act under the National Faceless Assessment Scheme (NaFAC / NFAC) - The provisions of Section 124 stipulate that when an assessee calls in question the jurisdiction of the AO - If the right to call in question the jurisdiction is left open to be raised at any stage, the proceedings will remain inconclusive and that could not have been the intendment of the legislature. Therefore, this Court must opine that the petitioner must fail - HC
Jurisdiction of the Income Tax authority to issue notice u/s 143[2] of the IT Act under the National Faceless Assessment Scheme (NaFAC / NFAC) - The provisions of Section 124 stipulate that when an assessee calls in question the jurisdiction of the AO - If the right to call in question the jurisdiction is left open to be raised at any stage, the proceedings will remain inconclusive and that could not have been the intendment of the legislature. Therefore, this Court must opine that the petitioner must fail - HC
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