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...
ITAT held that repeated non-compliances of multiple notices issued u/s 142(1) on the same subject constitute a single default for purposes of penalty u/s 271(1)(b). Accepting the assessee's plea, the Tribunal ruled that successive notices seeking identical information do not multiply the default. Applying s. 273B, it upheld penalty only for the first non-compliance and deleted penalty for the remaining four instances. The penalty was thus restricted to Rs. 10,000 for one default instead of five, and the assessee's appeal was partly allowed.
ITAT held that repeated non-compliances of multiple notices issued u/s 142(1) on the same subject constitute a single default for purposes of penalty u/s 271(1)(b). Accepting the assessee's plea, the Tribunal ruled that successive notices seeking identical information do not multiply the default. Applying s. 273B, it upheld penalty only for the first non-compliance and deleted penalty for the remaining four instances. The penalty was thus restricted to Rs. 10,000 for one default instead of five, and the assessee's appeal was partly allowed.
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TaxTMI 
TaxTMI 
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