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...
In limited scrutiny, the AO's jurisdiction is confined to the specific issues for which the case was selected. The Tribunal found that the scrutiny parameter referred only to transfer of property by the assessee and did not extend to acquisition or purchase of property. As there was no material showing a valid conversion of the assessment into complete scrutiny with approval of the competent authority, the addition for alleged unexplained investment in purchase of immovable property was beyond jurisdiction and contrary to the CBDT circular governing scrutiny assessments. The addition was therefore deleted and the appellate order set aside.
In limited scrutiny, the AO's jurisdiction is confined to the specific issues for which the case was selected. The Tribunal found that the scrutiny parameter referred only to transfer of property by the assessee and did not extend to acquisition or purchase of property. As there was no material showing a valid conversion of the assessment into complete scrutiny with approval of the competent authority, the addition for alleged unexplained investment in purchase of immovable property was beyond jurisdiction and contrary to the CBDT circular governing scrutiny assessments. The addition was therefore deleted and the appellate order set aside.
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TaxTMI 
TaxTMI 
of 4918 
