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...
Reopening of assessment - Disallowance of deduction claimed u/s 35(1)(ii) - The tribunal upheld the reopening of the assessment, ruling it as a procedural irregularity that does not invalidate the proceedings, and found no merit in the assessee's objections regarding the entitlement to deductions u/s 35(1)(ii), emphasizing the necessity for donations to be made to genuine institutions for claiming such deductions.
Reopening of assessment - Disallowance of deduction claimed u/s 35(1)(ii) - The tribunal upheld the reopening of the assessment, ruling it as a procedural irregularity that does not invalidate the proceedings, and found no merit in the assessee's objections regarding the entitlement to deductions u/s 35(1)(ii), emphasizing the necessity for donations to be made to genuine institutions for claiming such deductions.
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