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 quashed CIT(E)'s revision order under section 263, holding that the Commissioner cannot exercise revisional jurisdiction when identical issues are pending appeal before CIT(A). The tribunal applied the Doctrine of Merger, emphasizing that only one operative order can govern the same subject matter simultaneously. Since the assessment order under section 143(3) was not found erroneous or prejudicial to revenue's interests, the revisional order was set aside. The assessee's appeal was allowed, reinforcing procedural limitations on revisional powers when appellate proceedings are ongoing.
ITAT quashed CIT(E)'s revision order under section 263, holding that the Commissioner cannot exercise revisional jurisdiction when identical issues are pending appeal before CIT(A). The tribunal applied the Doctrine of Merger, emphasizing that only one operative order can govern the same subject matter simultaneously. Since the assessment order under section 143(3) was not found erroneous or prejudicial to revenue's interests, the revisional order was set aside. The assessee's appeal was allowed, reinforcing procedural limitations on revisional powers when appellate proceedings are ongoing.
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TaxTMI 
TaxTMI 
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