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...
Penalty u/s 271(1)(c) - The Appellate Tribunal observed that the appellant, during reassessment proceedings, had filed their return of income but failed to provide sufficient documentation to substantiate claimed expenses. Notably, the assessing officer disallowed 50% of the claimed expenses, but did not specifically charge the appellant with concealing income or furnishing inaccurate particulars in the assessment order. In the subsequent penalty order, the assessing officer invoked twin charges without clear evidence to support them. Considering the lack of specific charges and evidence, the Tribunal directed the assessing officer to delete the penalty.
Penalty u/s 271(1)(c) - The Appellate Tribunal observed that the appellant, during reassessment proceedings, had filed their return of income but failed to provide sufficient documentation to substantiate claimed expenses. Notably, the assessing officer disallowed 50% of the claimed expenses, but did not specifically charge the appellant with concealing income or furnishing inaccurate particulars in the assessment order. In the subsequent penalty order, the assessing officer invoked twin charges without clear evidence to support them. Considering the lack of specific charges and evidence, the Tribunal directed the assessing officer to delete the penalty.
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