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...
The ITAT set aside the question of depreciation on goodwill arising from amalgamation and remitted the matter to the file of the CIT(A) for de novo consideration, holding that the CIT(A) made no specific finding because the assessee failed to furnish essential documents (amalgamation order, pre- and post-amalgamation financials, goodwill computation) and did not dispute those facts. The CIT(A) is directed to call for the requisite documents, afford the assessee a fresh opportunity of hearing, and decide the issue on merits after considering any material the assessee may tender. The appeals of the assessee are allowed for statistical purposes.
The ITAT set aside the question of depreciation on goodwill arising from amalgamation and remitted the matter to the file of the CIT(A) for de novo consideration, holding that the CIT(A) made no specific finding because the assessee failed to furnish essential documents (amalgamation order, pre- and post-amalgamation financials, goodwill computation) and did not dispute those facts. The CIT(A) is directed to call for the requisite documents, afford the assessee a fresh opportunity of hearing, and decide the issue on merits after considering any material the assessee may tender. The appeals of the assessee are allowed for statistical purposes.
Note: It is a system-generated summary and is for quick reference only.