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...
The ITAT set aside the order passed by the CIT/NFAC under section 250 in proceedings initiated under sections 147 read with 144 and 144B, concerning unexplained cash deposits during the demonetization period. The assessee failed to appear or submit written arguments before the CIT(A), who also did not issue a speaking order as required by section 250(6). Citing precedent, the ITAT held that the CIT(A) must dispose of the appeal on merits, even if ex parte. Consequently, the ITAT restored the matter to the CIT(A) for fresh adjudication on merits and directed issuance of a speaking order in compliance with statutory requirements. The appeal was allowed for statistical purposes.
The ITAT set aside the order passed by the CIT/NFAC under section 250 in proceedings initiated under sections 147 read with 144 and 144B, concerning unexplained cash deposits during the demonetization period. The assessee failed to appear or submit written arguments before the CIT(A), who also did not issue a speaking order as required by section 250(6). Citing precedent, the ITAT held that the CIT(A) must dispose of the appeal on merits, even if ex parte. Consequently, the ITAT restored the matter to the CIT(A) for fresh adjudication on merits and directed issuance of a speaking order in compliance with statutory requirements. The appeal was allowed for statistical purposes.
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TaxTMI 
TaxTMI 
of 4918 
