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...
Revision u/s 263 - Method of accounting adopted for revenue recognition of the project - The Tribunal decided that the Pr.CIT erred in directing the AO to reassess based on the method of accounting adopted for revenue recognition. It noted that the appellant had consistently followed the project completion method, which had been accepted by the revenue authorities in the past, and the AO had applied his mind to this issue in the assessment. The Tribunal set aside the Pr.CIT's order on this issue, ruling in favor of the appellant.
Revision u/s 263 - Method of accounting adopted for revenue recognition of the project - The Tribunal decided that the Pr.CIT erred in directing the AO to reassess based on the method of accounting adopted for revenue recognition. It noted that the appellant had consistently followed the project completion method, which had been accepted by the revenue authorities in the past, and the AO had applied his mind to this issue in the assessment. The Tribunal set aside the Pr.CIT's order on this issue, ruling in favor of the appellant.
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TaxTMI 
TaxTMI 
of 4918 
