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...
Delay of 294 days in filing Special Leave Petition deemed invalid. Reopening of assessment u/s 143(3) without proper sanction u/s 151(1) from competent authority. Income Tax Officer obtained satisfaction from Additional Commissioner, an authority not covered by Section 151(1). Writ petition under Article 226 maintainable due to non-fulfillment of pre-conditions for exercise of power u/s 148. Application seeking condonation of delay dismissed by Supreme Court due to unsatisfactory explanation, consequently dismissing Special Leave Petition on ground of delay.
Delay of 294 days in filing Special Leave Petition deemed invalid. Reopening of assessment u/s 143(3) without proper sanction u/s 151(1) from competent authority. Income Tax Officer obtained satisfaction from Additional Commissioner, an authority not covered by Section 151(1). Writ petition under Article 226 maintainable due to non-fulfillment of pre-conditions for exercise of power u/s 148. Application seeking condonation of delay dismissed by Supreme Court due to unsatisfactory explanation, consequently dismissing Special Leave Petition on ground of delay.
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TaxTMI 
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