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 appeal and set aside the penalty imposed under section 271F. The Tribunal accepted the assessee's plea that failure to file the return under section 139(1) for the relevant assessment year was due to reasonable cause within the meaning of section 273B, namely that the assessee was wholly occupied assisting a close family member through acute legal and emotional distress coinciding with the filing deadline. Noting the absence of appellate concurrence by the CIT(A.) on the point of reasonable cause and considering the facts, ITAT held the levy by the AO and confirmation by the CIT(A.) unjustified and deleted the penalty; Ground No.1 allowed.
ITAT allowed the appeal and set aside the penalty imposed under section 271F. The Tribunal accepted the assessee's plea that failure to file the return under section 139(1) for the relevant assessment year was due to reasonable cause within the meaning of section 273B, namely that the assessee was wholly occupied assisting a close family member through acute legal and emotional distress coinciding with the filing deadline. Noting the absence of appellate concurrence by the CIT(A.) on the point of reasonable cause and considering the facts, ITAT held the levy by the AO and confirmation by the CIT(A.) unjustified and deleted the penalty; Ground No.1 allowed.
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