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...
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Revision u/s 263 by CIT - Addition u/s 68 - unexplained credit - The Tribunal meticulously examined the submissions, the audit objections, and the law's provisions. It observed that the appellant had indeed furnished comprehensive details during the original assessment proceedings. Notably, the Tribunal found that the Pr.CIT's reliance on audit objections and the subsequent show cause notice under Section 263 lacked independent application of mind. - The Tribunal held that the original assessment order made after due inquiries by the AO, which included scrutiny of unsecured loans and trade payables, could not be deemed erroneous merely because the Pr.CIT had a different view.
Revision u/s 263 by CIT - Addition u/s 68 - unexplained credit - The Tribunal meticulously examined the submissions, the audit objections, and the law's provisions. It observed that the appellant had indeed furnished comprehensive details during the original assessment proceedings. Notably, the Tribunal found that the Pr.CIT's reliance on audit objections and the subsequent show cause notice under Section 263 lacked independent application of mind. - The Tribunal held that the original assessment order made after due inquiries by the AO, which included scrutiny of unsecured loans and trade payables, could not be deemed erroneous merely because the Pr.CIT had a different view.
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