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...
Delay of 1154 days in filing appeal before Commissioner of Income Tax (Appeals) was not condoned as reasons given, such as leaving income tax matters in hands of Chartered Accountant, ignorance of law, and being busy with agricultural and household activities, did not constitute "sufficient cause" u/s 249(3). Appellant remained inactive and grossly negligent after receiving assessment order, lacking due diligence. Such casual and lackadaisical approach against assessment order and consequential delay in filing appeal would not constitute "sufficient cause" u/s 249(3). Decision of Commissioner of Income Tax (Appeals) refusing to condone delay upheld.
Delay of 1154 days in filing appeal before Commissioner of Income Tax (Appeals) was not condoned as reasons given, such as leaving income tax matters in hands of Chartered Accountant, ignorance of law, and being busy with agricultural and household activities, did not constitute "sufficient cause" u/s 249(3). Appellant remained inactive and grossly negligent after receiving assessment order, lacking due diligence. Such casual and lackadaisical approach against assessment order and consequential delay in filing appeal would not constitute "sufficient cause" u/s 249(3). Decision of Commissioner of Income Tax (Appeals) refusing to condone delay upheld.
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