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...
Revisional jurisdiction under section 263 was examined: the twin conditions of the order being erroneous and prejudicial to revenue were not met because the Assessing Officer issued detailed queries, obtained submissions and documents, and applied his mind before accepting returned income. Explanation 2(a) did not apply as inquiries were made. Clause (d) of Explanation 2 could not be invoked since the AO adopted a plausible view supported by High Court precedents and the Supreme Court decision relied on was distinguishable on its facts. The Tribunal set aside the Principal Commissioner's revision order and allowed the assessee's appeal.
Revisional jurisdiction under section 263 was examined: the twin conditions of the order being erroneous and prejudicial to revenue were not met because the Assessing Officer issued detailed queries, obtained submissions and documents, and applied his mind before accepting returned income. Explanation 2(a) did not apply as inquiries were made. Clause (d) of Explanation 2 could not be invoked since the AO adopted a plausible view supported by High Court precedents and the Supreme Court decision relied on was distinguishable on its facts. The Tribunal set aside the Principal Commissioner's revision order and allowed the assessee's appeal.
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