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...
Maintainability of revenue appeals before the Tribunal when the tax effect is below a certain threshold. According to CBDT instructions, subordinate authorities should not challenge CIT(Appeals) orders before the Tribunal if the tax effect due to relief granted is less than Rs. 60,00,000, unless the case falls within specified exceptions. In the instant case, since the tax effect is below the threshold and no exceptions apply, the revenue appeal is dismissed for lack of tax effect. However, if upon re-verification the tax effect exceeds the limit or an exception applies, the Revenue can file a miscellaneous application to revive the appeal.
Maintainability of revenue appeals before the Tribunal when the tax effect is below a certain threshold. According to CBDT instructions, subordinate authorities should not challenge CIT(Appeals) orders before the Tribunal if the tax effect due to relief granted is less than Rs. 60,00,000, unless the case falls within specified exceptions. In the instant case, since the tax effect is below the threshold and no exceptions apply, the revenue appeal is dismissed for lack of tax effect. However, if upon re-verification the tax effect exceeds the limit or an exception applies, the Revenue can file a miscellaneous application to revive the appeal.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4921 
