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 - another possible view of the matter - The appellant challenged the jurisdiction of the PCIT, arguing that the original assessment order by the AO was not erroneous and did not prejudice the revenue. - The ITAT found that the AO had duly examined the submissions and evidence before concluding the assessment. The PCIT's order was deemed unsustainable as it was based on grounds not part of the initial reasons for scrutiny and lacked sufficient basis. Consequently, the Tribunal set aside the PCIT's order and upheld the decision of the AO.
Revision u/s 263 - another possible view of the matter - The appellant challenged the jurisdiction of the PCIT, arguing that the original assessment order by the AO was not erroneous and did not prejudice the revenue. - The ITAT found that the AO had duly examined the submissions and evidence before concluding the assessment. The PCIT's order was deemed unsustainable as it was based on grounds not part of the initial reasons for scrutiny and lacked sufficient basis. Consequently, the Tribunal set aside the PCIT's order and upheld the decision of the AO.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4921 
