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...
Whether disallowance under section 14A read with Rule 8D required prior recording of satisfaction: held that s.14A(2) mandates that the assessing officer must record satisfaction or dissatisfaction regarding the correctness of expenditure claimed before making an addition; absence of such recorded dissatisfaction renders the disallowance impermissible. Applying this legal precondition, the Tribunal and the appellate tax authority's factual findings rejecting the Revenue's adjustment were upheld and the Revenue's appeal dismissed. - HC
Whether disallowance under section 14A read with Rule 8D required prior recording of satisfaction: held that s.14A(2) mandates that the assessing officer must record satisfaction or dissatisfaction regarding the correctness of expenditure claimed before making an addition; absence of such recorded dissatisfaction renders the disallowance impermissible. Applying this legal precondition, the Tribunal and the appellate tax authority's factual findings rejecting the Revenue's adjustment were upheld and the Revenue's appeal dismissed. - HC
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