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...
Under Section 144C the Dispute Resolution Panel (DRP) should have dismissed the petitioner's objections simpliciter because a final assessment order had already been passed; therefore the DRP's findings on whether the objections were intimated to the assessing officer were unwarranted. The operative effect directed is that those DRP observations shall not be considered by the Commissioner of Income Tax (Appeals), who must decide the taxpayer's appeal against the final assessment order without being influenced by the impugned DRP order.
Under Section 144C the Dispute Resolution Panel (DRP) should have dismissed the petitioner's objections simpliciter because a final assessment order had already been passed; therefore the DRP's findings on whether the objections were intimated to the assessing officer were unwarranted. The operative effect directed is that those DRP observations shall not be considered by the Commissioner of Income Tax (Appeals), who must decide the taxpayer's appeal against the final assessment order without being influenced by the impugned DRP order.
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