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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The Appellate Tribunal considered the condonation of a 335-day delay in filing an appeal before the CIT (A). The assessee's explanation, including difficulties related to obtaining documents from Norway and the impact of the Covid-19 pandemic, was deemed sufficient. The Tribunal found no intentional delay or negligence on the part of the assessee. Citing Supreme Court precedent, the Tribunal disagreed with the First Appellate Authority's rejection of the explanation. The case was remitted to the CIT (A) for fresh adjudication, with the directive to consider all relevant evidence and provide the assessee with a hearing. The appeal was allowed for statistical purposes.
The Appellate Tribunal considered the condonation of a 335-day delay in filing an appeal before the CIT (A). The assessee's explanation, including difficulties related to obtaining documents from Norway and the impact of the Covid-19 pandemic, was deemed sufficient. The Tribunal found no intentional delay or negligence on the part of the assessee. Citing Supreme Court precedent, the Tribunal disagreed with the First Appellate Authority's rejection of the explanation. The case was remitted to the CIT (A) for fresh adjudication, with the directive to consider all relevant evidence and provide the assessee with a hearing. The appeal was allowed for statistical purposes.
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