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-filer assessee had taxable income but failed to file return u/s 139(1), later filed return in response to notice u/s 148 without considering section 50C provisions, amounting to concealment of income. Assessee neither filed explanation nor appeared before authorities during assessment or penalty proceedings u/s 271(1)(c) despite show cause notices. No reasonable cause furnished for non-filing of return or non-appearance. Penalty u/s 271(1)(c) confirmed as assessee concealed particulars of income by not adopting section 50C provisions while computing capital gains based on registered sale deed value.
Non-filer assessee had taxable income but failed to file return u/s 139(1), later filed return in response to notice u/s 148 without considering section 50C provisions, amounting to concealment of income. Assessee neither filed explanation nor appeared before authorities during assessment or penalty proceedings u/s 271(1)(c) despite show cause notices. No reasonable cause furnished for non-filing of return or non-appearance. Penalty u/s 271(1)(c) confirmed as assessee concealed particulars of income by not adopting section 50C provisions while computing capital gains based on registered sale deed value.
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