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 allowed the assessee's appeal against CIT's revision u/s 263. The tribunal found no jurisdictional defect as the assessee consistently responded to notices from ITO Panchkula without raising objections. The AO conducted limited scrutiny, sought explanations on unsecured loans and credit card payments, and was satisfied with the assessee's evidence. CIT's general observations lacked specific errors, and the assumption of complete scrutiny was incorrect. The tribunal held that CIT erroneously invoked section 263, thereby quashing the revisional order and upholding the original assessment.
ITAT allowed the assessee's appeal against CIT's revision u/s 263. The tribunal found no jurisdictional defect as the assessee consistently responded to notices from ITO Panchkula without raising objections. The AO conducted limited scrutiny, sought explanations on unsecured loans and credit card payments, and was satisfied with the assessee's evidence. CIT's general observations lacked specific errors, and the assumption of complete scrutiny was incorrect. The tribunal held that CIT erroneously invoked section 263, thereby quashing the revisional order and upholding the original assessment.
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TaxTMI 
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