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...
Penalty u/s 271(1)(b) imposed on minor - The tribunal upheld the appellant's argument regarding being a minor, stating that penalty proceedings initiated against a minor without the consent of their guardian are not legally sustainable. Considering this and the lack of additions in the quantum proceedings, the tribunal ruled in favor of the appellant, deleting the remaining penalty amount.
Penalty u/s 271(1)(b) imposed on minor - The tribunal upheld the appellant's argument regarding being a minor, stating that penalty proceedings initiated against a minor without the consent of their guardian are not legally sustainable. Considering this and the lack of additions in the quantum proceedings, the tribunal ruled in favor of the appellant, deleting the remaining penalty amount.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4921 
