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...
ITAT recalled its earlier order due to discovery of inadvertent errors, specifically the reliance on non-existing case laws identified during suo-moto review. Exercising powers under s.254(2) of the Act, the Tribunal vacated the entire order and scheduled a fresh hearing. The matter involves jurisdictional authority to rectify mistakes apparent from record, which extends to substantive errors in legal reasoning. The recall order demonstrates ITAT's inherent power to correct decisions based on erroneous application of non-existent precedents. Fresh notices issued to
ITAT recalled its earlier order due to discovery of inadvertent errors, specifically the reliance on non-existing case laws identified during suo-moto review. Exercising powers under s.254(2) of the Act, the Tribunal vacated the entire order and scheduled a fresh hearing. The matter involves jurisdictional authority to rectify mistakes apparent from record, which extends to substantive errors in legal reasoning. The recall order demonstrates ITAT's inherent power to correct decisions based on erroneous application of non-existent precedents. Fresh notices issued to
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TaxTMI 
TaxTMI 
of 4918 
