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...
Revision u/s 263 challenged for lack of proper inquiry by Assessing Officer regarding cash deposits during demonetization, scrap sales, and non-submission of audit report. ITAT set aside revision order. Substantial question of law raised. Held that department only challenged factual findings of Tribunal. Supreme Court precedents establish that no substantial question of law arises from factual findings unless perverse. Perversity defined as finding without evidence, unreasonable, based on surmises or suspicion. Tribunal's factual finding perverse only if affecting substantial rights of assessee unreasonably based on record. Tribunal examined facts in detail before ruling in assessee's favor. No perversity found in Tribunal's fact finding.
Revision u/s 263 challenged for lack of proper inquiry by Assessing Officer regarding cash deposits during demonetization, scrap sales, and non-submission of audit report. ITAT set aside revision order. Substantial question of law raised. Held that department only challenged factual findings of Tribunal. Supreme Court precedents establish that no substantial question of law arises from factual findings unless perverse. Perversity defined as finding without evidence, unreasonable, based on surmises or suspicion. Tribunal's factual finding perverse only if affecting substantial rights of assessee unreasonably based on record. Tribunal examined facts in detail before ruling in assessee's favor. No perversity found in Tribunal's fact finding.
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TaxTMI 
TaxTMI 
of 4918 
