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...
Refund claim denied u/s 239(2)(c) as assessee filed return after one year from last date of relevant assessment year. Assessee contended case covered u/s 240 as refund consequent to appellate order. Held, Section 239 applies to refund by self-assessment, Section 240 covers refund pursuant to appellate order. ACIT passed order u/ss 251/154/147/143(3) determining refund. Assessee's case covered u/s 240, not Section 239. Orders of AO and CIT(A) set aside, assessee entitled to refund of Rs. 27,04,767/-. Appeal allowed.
Refund claim denied u/s 239(2)(c) as assessee filed return after one year from last date of relevant assessment year. Assessee contended case covered u/s 240 as refund consequent to appellate order. Held, Section 239 applies to refund by self-assessment, Section 240 covers refund pursuant to appellate order. ACIT passed order u/ss 251/154/147/143(3) determining refund. Assessee's case covered u/s 240, not Section 239. Orders of AO and CIT(A) set aside, assessee entitled to refund of Rs. 27,04,767/-. Appeal allowed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
