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...
ITAT determined CPC's unilateral reduction of TDS credit was improper after previously granting full credit in three separate rectification orders. The subsequent reduction, executed without prior notice to assessee, violated Section 154 procedural requirements and principles of natural justice. CPC's action of diminishing TDS credit and raising demand without show cause notice was deemed unjustified. ITAT set aside CIT(A)'s order, directing AO/CPC to restore complete TDS credit and nullify corresponding demand. The assessee's appeal succeeded, establishing that administrative modifications to tax credits require proper notice and opportunity for response, upholding procedural fairness in tax proceedings.
ITAT determined CPC's unilateral reduction of TDS credit was improper after previously granting full credit in three separate rectification orders. The subsequent reduction, executed without prior notice to assessee, violated Section 154 procedural requirements and principles of natural justice. CPC's action of diminishing TDS credit and raising demand without show cause notice was deemed unjustified. ITAT set aside CIT(A)'s order, directing AO/CPC to restore complete TDS credit and nullify corresponding demand. The assessee's appeal succeeded, establishing that administrative modifications to tax credits require proper notice and opportunity for response, upholding procedural fairness in tax proceedings.
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TaxTMI 
TaxTMI 
of 4918 
