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...
Doctrine of merger - Validity of Revision u/s 263 when existing pending appeal against order passed u/s 153C r.w.s. 144 - when larger issue was pending before CIT(A), the revisionary authority could not exercise jurisdiction u/s 263. thus we would hold that the impugned revision u/s 263 was bad-in-law - AT
Doctrine of merger - Validity of Revision u/s 263 when existing pending appeal against order passed u/s 153C r.w.s. 144 - when larger issue was pending before CIT(A), the revisionary authority could not exercise jurisdiction u/s 263. thus we would hold that the impugned revision u/s 263 was bad-in-law - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
