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...
Penalty under section 272A(1)(d) for non-compliance with a statutory notice was deleted by the ITAT. The Tribunal noted that the quantum assessment had already been restored to the Assessing Officer for de novo consideration and, although that restoration did not directly determine the non-appearance issue, it considered the assessee's consistent follow-up with the tax authorities in other matters. On that overall conduct and in the interests of justice, the Tribunal directed deletion of the penalty and allowed the appeal.
Penalty under section 272A(1)(d) for non-compliance with a statutory notice was deleted by the ITAT. The Tribunal noted that the quantum assessment had already been restored to the Assessing Officer for de novo consideration and, although that restoration did not directly determine the non-appearance issue, it considered the assessee's consistent follow-up with the tax authorities in other matters. On that overall conduct and in the interests of justice, the Tribunal directed deletion of the penalty and allowed the appeal.
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