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 u/s 147/148 - reasons to believe - The Tribunal upheld the validity of the reopening, considering the reasons recorded by the Assessing Officer as based on tangible material. While the assessee failed to provide satisfactory evidence to explain the cash deposits, the Tribunal allowed partial relief by directing a 10% disallowance of the balance amount of the addition. The Tribunal's decision aimed at ensuring fairness and justice, taking into account the circumstances of the case.
Reopening of assessment u/s 147/148 - reasons to believe - The Tribunal upheld the validity of the reopening, considering the reasons recorded by the Assessing Officer as based on tangible material. While the assessee failed to provide satisfactory evidence to explain the cash deposits, the Tribunal allowed partial relief by directing a 10% disallowance of the balance amount of the addition. The Tribunal's decision aimed at ensuring fairness and justice, taking into account the circumstances of the case.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
