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...
Interest payable to petitioner u/s 244A - Failure on the part of AO to comply with the decisions / principles given by the ITAT and High Court - The Court emphasized that the Assessing Officer's role was to implement the directions of the Tribunal, not to question or dissect them. Mr. Singhania's actions went beyond his jurisdiction, leading to incorrect conclusions regarding the payment of interest under Section 244A.
Interest payable to petitioner u/s 244A - Failure on the part of AO to comply with the decisions / principles given by the ITAT and High Court - The Court emphasized that the Assessing Officer's role was to implement the directions of the Tribunal, not to question or dissect them. Mr. Singhania's actions went beyond his jurisdiction, leading to incorrect conclusions regarding the payment of interest under Section 244A.
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TaxTMI 
TaxTMI 
of 4918 
