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 examined on whether the AO failed to make requisite enquiries or made inadequate enquiries; the tribunal found the AO had verified seized materials, recorded the assessee's statement and considered explanations, so the basis for revisional jurisdiction was absent and the PCIT's order could not be sustained. The requirement that a revisional order be founded on objective material and specific findings, not mere subjective dissatisfaction or the brevity of the AO's order, was emphasized; consequently the revisional action was quashed and the appeal allowed.
Revision under section 263 was examined on whether the AO failed to make requisite enquiries or made inadequate enquiries; the tribunal found the AO had verified seized materials, recorded the assessee's statement and considered explanations, so the basis for revisional jurisdiction was absent and the PCIT's order could not be sustained. The requirement that a revisional order be founded on objective material and specific findings, not mere subjective dissatisfaction or the brevity of the AO's order, was emphasized; consequently the revisional action was quashed and the appeal allowed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4921 
