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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Scope of adjustments u/s. 143(1) - Applicability of presumptive provisions of tax u/s. 44ADA - The Tribunal observed that the appellant had not disclosed the income on a presumptive basis u/s. 44ADA but under u/s. 44AD. It was deemed that the Central Processing Centre (CPC) had exceeded its scope of power of adjustment prescribed u/s. 143(1) by invoking the provisions of section 44ADA. Consequently, the adjustment made by the CPC was set aside, and the appeal was allowed.
Scope of adjustments u/s. 143(1) - Applicability of presumptive provisions of tax u/s. 44ADA - The Tribunal observed that the appellant had not disclosed the income on a presumptive basis u/s. 44ADA but under u/s. 44AD. It was deemed that the Central Processing Centre (CPC) had exceeded its scope of power of adjustment prescribed u/s. 143(1) by invoking the provisions of section 44ADA. Consequently, the adjustment made by the CPC was set aside, and the appeal was allowed.
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