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...
Assessee surrendered income during survey u/s 133A as unaccounted professional receipts, which AO accepted as professional income taxable at normal rates. PCIT invoked revision u/s 263, alleging AO didn't inquire about surrendered income's nature. ITAT held PCIT's finding unsustainable as AO conducted due inquiry, assessee voluntarily surrendered professional receipts, disclosed and audited them, and AO's acceptance accorded with judicial precedents. PCIT didn't examine survey records to substantiate error, merely stating AO didn't inquire without evidence. ITAT ruled PCIT lacked valid jurisdiction for revision.
Assessee surrendered income during survey u/s 133A as unaccounted professional receipts, which AO accepted as professional income taxable at normal rates. PCIT invoked revision u/s 263, alleging AO didn't inquire about surrendered income's nature. ITAT held PCIT's finding unsustainable as AO conducted due inquiry, assessee voluntarily surrendered professional receipts, disclosed and audited them, and AO's acceptance accorded with judicial precedents. PCIT didn't examine survey records to substantiate error, merely stating AO didn't inquire without evidence. ITAT ruled PCIT lacked valid jurisdiction for revision.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
