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...
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Where registered sale deeds were cancelled and consideration reversed but those documents were not placed before the assessing officer during assessment proceedings, cancelled transactions were treated as not giving rise to taxable income. The document stresses that evidence of cancellation and reversal, when first produced only before the court, defeats assessment orders premised on the original transactions. The assessing officer's failure to consider cancellation and reversal rendered impugned assessment orders unsustainable, resulting in quashing and setting aside of those orders and disposal in light of the cited precedent.
Where registered sale deeds were cancelled and consideration reversed but those documents were not placed before the assessing officer during assessment proceedings, cancelled transactions were treated as not giving rise to taxable income. The document stresses that evidence of cancellation and reversal, when first produced only before the court, defeats assessment orders premised on the original transactions. The assessing officer's failure to consider cancellation and reversal rendered impugned assessment orders unsustainable, resulting in quashing and setting aside of those orders and disposal in light of the cited precedent.
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