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 271(1)(c) could not survive once the underlying quantum addition, which formed the sole basis of the penalty, had already been deleted in the assessee's own case and that fact was not disputed by the Revenue. The Tribunal treated the penalty as purely consequential to the assessment addition and held that, without a surviving addition, there was no basis to sustain the penalty. The order sustaining the penalty was set aside and the penalty deleted.
Penalty under section 271(1)(c) could not survive once the underlying quantum addition, which formed the sole basis of the penalty, had already been deleted in the assessee's own case and that fact was not disputed by the Revenue. The Tribunal treated the penalty as purely consequential to the assessment addition and held that, without a surviving addition, there was no basis to sustain the penalty. The order sustaining the penalty was set aside and the penalty deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
