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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Revision u/s 263 - order framed u/s 153A - The Tribunal (ITAT) held that, the assessment orders approved u/s 153D cannot be revised u/s 263 without first revising the approval itself. The AO conducted adequate and reasonable enquiries, fulfilling the requirements of a proper assessment. - The Tribunal emphasized the legal principle that when two views are possible, the AO's decision to adopt one permissible view cannot be deemed erroneous or prejudicial to the interests of the revenue.
Revision u/s 263 - order framed u/s 153A - The Tribunal (ITAT) held that, the assessment orders approved u/s 153D cannot be revised u/s 263 without first revising the approval itself. The AO conducted adequate and reasonable enquiries, fulfilling the requirements of a proper assessment. - The Tribunal emphasized the legal principle that when two views are possible, the AO's decision to adopt one permissible view cannot be deemed erroneous or prejudicial to the interests of the revenue.
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