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...
Impugned order quashed due to violation of principles of natural justice as second notice failed to mention time or date for personal hearing. Case remitted to pass fresh orders on merits and in accordance with law within 60 days, treating impugned order as addendum to preceding show cause notice, considering recovery of Rs. 38 lakhs from petitioner's account.
Impugned order quashed due to violation of principles of natural justice as second notice failed to mention time or date for personal hearing. Case remitted to pass fresh orders on merits and in accordance with law within 60 days, treating impugned order as addendum to preceding show cause notice, considering recovery of Rs. 38 lakhs from petitioner's account.
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