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...
Refund adjustment against a disputed penalty demand pending first appeal is ordinarily limited to 20% under CBDT stay guidelines. The guidelines do not distinguish assessment demands from penalty demands, so full adjustment before pending stay applications are decided conflicts with those instructions. Recovery should therefore be confined to 20% of the disputed penalty demand, with excess adjustment reversed and refunded with applicable interest and the balance demand stayed pending disposal of the first appeal.
Refund adjustment against a disputed penalty demand pending first appeal is ordinarily limited to 20% under CBDT stay guidelines. The guidelines do not distinguish assessment demands from penalty demands, so full adjustment before pending stay applications are decided conflicts with those instructions. Recovery should therefore be confined to 20% of the disputed penalty demand, with excess adjustment reversed and refunded with applicable interest and the balance demand stayed pending disposal of the first appeal.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
