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...
The case involves timeliness of appeal filed u/s 85(3A) of Finance Act, 1994 before Commissioner (Appeals-II) and refund claim. The Appellate Tribunal found that the appellant had submitted appeal papers to Sevottam section, but factual position on receipt was unclear. The Commissioner (Appeals) did not examine merits, solely citing delay. Considering the acknowledgment of receipt, the Tribunal allowed the appeal, condoning the delay and remanding for detailed examination on merits. The impugned order was set aside, and the case was remanded for a fresh decision by the Commissioner (Appeals-II).
The case involves timeliness of appeal filed u/s 85(3A) of Finance Act, 1994 before Commissioner (Appeals-II) and refund claim. The Appellate Tribunal found that the appellant had submitted appeal papers to Sevottam section, but factual position on receipt was unclear. The Commissioner (Appeals) did not examine merits, solely citing delay. Considering the acknowledgment of receipt, the Tribunal allowed the appeal, condoning the delay and remanding for detailed examination on merits. The impugned order was set aside, and the case was remanded for a fresh decision by the Commissioner (Appeals-II).
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