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 - The Assessee argued that the assessments u/s 143(1) and 143(3) merged, precluding further additions u/s 154, while the Revenue contended that they were distinct assessments. The Tribunal found that there was no merger between the assessments and upheld the validity of the rectification u/s 154. It concluded that the additions made under Section 143(1) were not revisited during the assessment u/s 143(3), necessitating rectification to correct the apparent error. The Tribunal differentiated the present case from previous precedents and dismissed the Assessee's appeal.
Rectification u/s 154 - The Assessee argued that the assessments u/s 143(1) and 143(3) merged, precluding further additions u/s 154, while the Revenue contended that they were distinct assessments. The Tribunal found that there was no merger between the assessments and upheld the validity of the rectification u/s 154. It concluded that the additions made under Section 143(1) were not revisited during the assessment u/s 143(3), necessitating rectification to correct the apparent error. The Tribunal differentiated the present case from previous precedents and dismissed the Assessee's appeal.
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