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...
CIT(A) erred in rejecting assessee's delay condonation request on technical grounds without considering assessee's absence from India until order receipt date. Assessee filed appeal within 30 days of returning to India, satisfying Section 249(2)(b) requirement. CIT(A) adopted pedantic approach, ignoring sufficient cause. Matter remanded to AO to decide afresh after issuing notice to assessee's updated address and email, allowing submissions. Assessee's lack of opportunity before AO also noted.
CIT(A) erred in rejecting assessee's delay condonation request on technical grounds without considering assessee's absence from India until order receipt date. Assessee filed appeal within 30 days of returning to India, satisfying Section 249(2)(b) requirement. CIT(A) adopted pedantic approach, ignoring sufficient cause. Matter remanded to AO to decide afresh after issuing notice to assessee's updated address and email, allowing submissions. Assessee's lack of opportunity before AO also noted.
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TaxTMI 
TaxTMI 
of 4921 
