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...
HC dismissed the assessee's appeal challenging PCIT's revision order under section 263. The assessee claimed LTCG exemption under section 10(38) on penny stock transactions. PCIT invoked Explanation 2(a) to section 263, finding the assessment order erroneous and prejudicial to revenue interest due to AO's failure to conduct adequate inquiry despite receiving investigation report identifying the company as penny stock operator. Tribunal upheld PCIT's direction for fresh assessment with proper verification. HC rejected assessee's contentions regarding availability of two views and breach of natural justice, holding concurrent findings justified as AO failed to make necessary inquiries regarding penny stock transactions before allowing LTCG exemption.
HC dismissed the assessee's appeal challenging PCIT's revision order under section 263. The assessee claimed LTCG exemption under section 10(38) on penny stock transactions. PCIT invoked Explanation 2(a) to section 263, finding the assessment order erroneous and prejudicial to revenue interest due to AO's failure to conduct adequate inquiry despite receiving investigation report identifying the company as penny stock operator. Tribunal upheld PCIT's direction for fresh assessment with proper verification. HC rejected assessee's contentions regarding availability of two views and breach of natural justice, holding concurrent findings justified as AO failed to make necessary inquiries regarding penny stock transactions before allowing LTCG exemption.
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