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 challenged the validity of an exemption claim under section 54 on grounds that the assessing officer failed to examine supporting materials; tribunal found the AO had issued a specific query under section 142(1), the assessee uploaded conveyance deed and supporting evidence in response, and assessment followed that examination. Consequently the reassessment order under section 263 was not sustainable because the assessment was not shown to be erroneous or prejudicial where relevant details were on record and considered. Reliance was placed on prior judicial authority supporting that record-based examination negates the ground for revision.
Revision under section 263 challenged the validity of an exemption claim under section 54 on grounds that the assessing officer failed to examine supporting materials; tribunal found the AO had issued a specific query under section 142(1), the assessee uploaded conveyance deed and supporting evidence in response, and assessment followed that examination. Consequently the reassessment order under section 263 was not sustainable because the assessment was not shown to be erroneous or prejudicial where relevant details were on record and considered. Reliance was placed on prior judicial authority supporting that record-based examination negates the ground for revision.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4921 
