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 HC upheld the appellate authorities' findings, holding that income computed pursuant to an APA executed under s.92CC is binding and, where the assessee voluntarily reported ALP-based adjustments in its return without enhancement by the AO under s.92C, the exemption under s.10AA remains available. The court reiterated that APAs remove valuation uncertainty for international transactions and are binding except in specified circumstances (change of law/facts, fraud/misrepresentation). The HC further held that the AO's adhoc 10% disallowance under s.14A lacked tangible basis; prior administrative acceptance of deletions and absence of prosecutable infirmity meant no substantial question of law arose for the appeals.
The HC upheld the appellate authorities' findings, holding that income computed pursuant to an APA executed under s.92CC is binding and, where the assessee voluntarily reported ALP-based adjustments in its return without enhancement by the AO under s.92C, the exemption under s.10AA remains available. The court reiterated that APAs remove valuation uncertainty for international transactions and are binding except in specified circumstances (change of law/facts, fraud/misrepresentation). The HC further held that the AO's adhoc 10% disallowance under s.14A lacked tangible basis; prior administrative acceptance of deletions and absence of prosecutable infirmity meant no substantial question of law arose for the appeals.
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