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...
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ITAT addressed disallowance of exemption under s54B where appellant failed to submit required documentation to CIT(A)/NFAC despite multiple notices. While notices were sent to appellant's CA's email, who failed to inform appellant, resulting in appeal dismissal for non-prosecution. ITAT, considering overall circumstances and interests of justice, remanded matter back to CIT(A)/NFAC with directions to grant appellant final opportunity to substantiate claim with requisite details. CIT(A)/NFAC directed to adjudicate based on facts and law after appellant's submission. Appeal allowed for statistical purposes, contingent on appellant's compliance with submission requirements on appointed date.
ITAT addressed disallowance of exemption under s54B where appellant failed to submit required documentation to CIT(A)/NFAC despite multiple notices. While notices were sent to appellant's CA's email, who failed to inform appellant, resulting in appeal dismissal for non-prosecution. ITAT, considering overall circumstances and interests of justice, remanded matter back to CIT(A)/NFAC with directions to grant appellant final opportunity to substantiate claim with requisite details. CIT(A)/NFAC directed to adjudicate based on facts and law after appellant's submission. Appeal allowed for statistical purposes, contingent on appellant's compliance with submission requirements on appointed date.
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