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...
Revision u/s 263 by CIT - the ITAT upheld the impugned order, dismissing the appeal of the assessee. The Tribunal ruled that the CIT had exercised revisional jurisdiction after independently examining the records and applying their mind to the case. Additionally, they found that the reference made by the Assessing Officer to the TPO was invalid due to the expiration of the time limit, making it no reference in the eyes of the law.
Revision u/s 263 by CIT - the ITAT upheld the impugned order, dismissing the appeal of the assessee. The Tribunal ruled that the CIT had exercised revisional jurisdiction after independently examining the records and applying their mind to the case. Additionally, they found that the reference made by the Assessing Officer to the TPO was invalid due to the expiration of the time limit, making it no reference in the eyes of the law.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
