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...
Non-issuance of ASMT-10 notice vitiated scrutiny conclusions but not adjudication as petitioner was provided opportunity to show cause - Tax proposal confirmed due to petitioner's failure to reply - Petitioner asserted unawareness of proceedings - Interest of justice warrants opportunity to contest tax demand on merits - Impugned assessment order set aside on condition of remitting 10% of disputed tax demand within 15 days and permitting petitioner to submit reply to show cause notice - Matter remanded for reconsideration in one case.
Non-issuance of ASMT-10 notice vitiated scrutiny conclusions but not adjudication as petitioner was provided opportunity to show cause - Tax proposal confirmed due to petitioner's failure to reply - Petitioner asserted unawareness of proceedings - Interest of justice warrants opportunity to contest tax demand on merits - Impugned assessment order set aside on condition of remitting 10% of disputed tax demand within 15 days and permitting petitioner to submit reply to show cause notice - Matter remanded for reconsideration in one case.
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