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...
Rectification u/s 154 - disallowance of carrying forward of the loss - The High Court examined the contentions of both parties and found merit in the petitioner's argument regarding the violation of Section 154(3) of the Act. It emphasized that any rectification adversely affecting the assessee's interests must be preceded by a notice and an opportunity to be heard. Since such compliance was lacking in the impugned order, the Court deemed it unsustainable and set it aside.
Rectification u/s 154 - disallowance of carrying forward of the loss - The High Court examined the contentions of both parties and found merit in the petitioner's argument regarding the violation of Section 154(3) of the Act. It emphasized that any rectification adversely affecting the assessee's interests must be preceded by a notice and an opportunity to be heard. Since such compliance was lacking in the impugned order, the Court deemed it unsustainable and set it aside.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
