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...
Notices issued to the email address recorded in the tax database were held valid in law; non-service cannot be attributed to the Assessing Officer where the assessee provided or allowed an inaccessible email ID, and the assessee bears the duty to furnish and monitor a valid communication address, but must still be afforded an opportunity to be heard. Where pandemic-related non-communication plausibly explains delayed compliance, delay in filing appeals to the CIT(A) was condoned and the appeals were restored for adjudication on merits, subject to a protective condition that the assessee deposit twenty percent of the demand; no fresh assessment or remand to the Assessing Officer was ordered.
Notices issued to the email address recorded in the tax database were held valid in law; non-service cannot be attributed to the Assessing Officer where the assessee provided or allowed an inaccessible email ID, and the assessee bears the duty to furnish and monitor a valid communication address, but must still be afforded an opportunity to be heard. Where pandemic-related non-communication plausibly explains delayed compliance, delay in filing appeals to the CIT(A) was condoned and the appeals were restored for adjudication on merits, subject to a protective condition that the assessee deposit twenty percent of the demand; no fresh assessment or remand to the Assessing Officer was ordered.
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