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...
Reasonable cause under Section 273B operates to preclude imposition of penalties under Sections 271D and 271E where the assessee demonstrably shows bona fide belief and genuineness of transactions; thus deposit of cash in bank accounts, explained as bona fide and not motivated to avoid tax, furnished a reasonable cause and led to relief from penalties. The tribunal applied the ordinary prudence standard for 'reasonable cause'-a cause beyond the assessee's control, without negligence or lack of bona fides-and allowed the appeal on that basis.
Reasonable cause under Section 273B operates to preclude imposition of penalties under Sections 271D and 271E where the assessee demonstrably shows bona fide belief and genuineness of transactions; thus deposit of cash in bank accounts, explained as bona fide and not motivated to avoid tax, furnished a reasonable cause and led to relief from penalties. The tribunal applied the ordinary prudence standard for 'reasonable cause'-a cause beyond the assessee's control, without negligence or lack of bona fides-and allowed the appeal on that basis.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
