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...
Revision under section 263 was invoked on the ground that the assessment under section 153C read with section 143(3) concerning alleged cash payment for purchase of development rights was erroneous and prejudicial. It was held that prior administrative approval under section 153D does not bar revision, since the statutory scheme permits the PCIT to revise an assessment order notwithstanding such approval. On merits, the assessment was found to be based on enquiries, verification of documents and evidences, and a plausible view, including consideration of a witness statement denying linkage of seized notings to the assessee; the Revenue also failed to identify any specific unmade enquiry or incriminating material directly implicating the assessee. Consequently, the revision order was set aside and the appeal was allowed - ITAT
Revision under section 263 was invoked on the ground that the assessment under section 153C read with section 143(3) concerning alleged cash payment for purchase of development rights was erroneous and prejudicial. It was held that prior administrative approval under section 153D does not bar revision, since the statutory scheme permits the PCIT to revise an assessment order notwithstanding such approval. On merits, the assessment was found to be based on enquiries, verification of documents and evidences, and a plausible view, including consideration of a witness statement denying linkage of seized notings to the assessee; the Revenue also failed to identify any specific unmade enquiry or incriminating material directly implicating the assessee. Consequently, the revision order was set aside and the appeal was allowed - ITAT
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