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...
Respondent-authorities failed to communicate reasons for retaining books of accounts and documents beyond statutory period of 30 days from assessment order as mandated u/s 132(8). Petitioner was deprived of opportunity to raise objections before Central Board of Direct Taxes u/s 132(10). Court held that non-communication of reasons for retention renders further retention illegal and invalid as per precedents. Respondents directed to return seized books and documents forthwith to petitioner.
Respondent-authorities failed to communicate reasons for retaining books of accounts and documents beyond statutory period of 30 days from assessment order as mandated u/s 132(8). Petitioner was deprived of opportunity to raise objections before Central Board of Direct Taxes u/s 132(10). Court held that non-communication of reasons for retention renders further retention illegal and invalid as per precedents. Respondents directed to return seized books and documents forthwith to petitioner.
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