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 invoked revisionary jurisdiction u/s 263 alleging AO did not examine provision for subcontracting expenses and refund claim during reassessment proceedings. Assessee contended queries were addressed u/s 133(6). ITAT held CIT cannot reappreciate same material considered by AO in reassessment, as legal presumption under Evidence Act exists that AO passed order properly. AO duly deliberated on subcontract expenses after issuing questionnaire. Refund issue was consequential to reassessment order without specific AO order, precluding CIT's jurisdiction u/s 263. Assessee cannot agitate Section 154 order not challenged. Case laws cited were distinguished on facts. Impugned CIT order set aside, assessee's appeal allowed.
CIT invoked revisionary jurisdiction u/s 263 alleging AO did not examine provision for subcontracting expenses and refund claim during reassessment proceedings. Assessee contended queries were addressed u/s 133(6). ITAT held CIT cannot reappreciate same material considered by AO in reassessment, as legal presumption under Evidence Act exists that AO passed order properly. AO duly deliberated on subcontract expenses after issuing questionnaire. Refund issue was consequential to reassessment order without specific AO order, precluding CIT's jurisdiction u/s 263. Assessee cannot agitate Section 154 order not challenged. Case laws cited were distinguished on facts. Impugned CIT order set aside, assessee's appeal allowed.
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TaxTMI 
TaxTMI 
of 4918 
