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...
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CBDT stay instructions limit recovery of a tax demand disputed before the First Appellate Authority to 20% as a pre-condition for stay. Refunds for later assessment years may not be adjusted against the disputed demand where prior payments and such adjustments have already recovered more than that threshold. Adjustment beyond 20% is impermissible, and the excess recovery must be refunded within four weeks while the first appeal remains pending.
CBDT stay instructions limit recovery of a tax demand disputed before the First Appellate Authority to 20% as a pre-condition for stay. Refunds for later assessment years may not be adjusted against the disputed demand where prior payments and such adjustments have already recovered more than that threshold. Adjustment beyond 20% is impermissible, and the excess recovery must be refunded within four weeks while the first appeal remains pending.
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