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...
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Credit of TDS - Non-reflection of TDS credit in its 26AS statement - The Appellate Tribunal acknowledged the genuine hardship faced by the appellant - While recognizing the technical constraints, the Tribunal suggests that the Assessing Officer should find a solution to address the appellant's hardship. The Tribunal directs the AO to verify the facts of the case and consider resorting to the provisions of Section 119 of the Income Tax Act, allowing the appellant to address its grievance through proper application.
Credit of TDS - Non-reflection of TDS credit in its 26AS statement - The Appellate Tribunal acknowledged the genuine hardship faced by the appellant - While recognizing the technical constraints, the Tribunal suggests that the Assessing Officer should find a solution to address the appellant's hardship. The Tribunal directs the AO to verify the facts of the case and consider resorting to the provisions of Section 119 of the Income Tax Act, allowing the appellant to address its grievance through proper application.
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