Transfer pricing comparability prioritises reliable external CUPs and foreign-currency LIBOR benchmarks for exports, borrowings and delayed receivable...
Section 153C satisfaction and seized electronic records sustained unexplained-investment addition, subject to proportionate ownership-share verificati...
Natural justice in insolvency-professional discipline requires disclosed material; notices based on extraneous material and ignored defences are vitia...
Reassessment after search was held time-barred for A.Y. 2013-14 because the ten-year limit under section 149 extended only up to A.Y. 2014-15. For A.Ys. 2014-15 to 2017-18, reopening beyond six years failed because the alleged escaped income was not represented as an asset, so jurisdiction was lacking. For A.Ys. 2018-19 to 2020-21, the notices were invalid since the income alleged did not satisfy the statutory conditions for reopening beyond three years under section 149(1)(b). The Tribunal also reduced the gross profit rate on unaccounted sales to 10% for A.Y. 2021-22, held the post-search assessment for A.Y. 2022-23 invalid for want of section 148/148B procedure, and deleted the section 41(1) addition for A.Y. 2023-24 as no cessation of liability was shown.
Reassessment after search was held time-barred for A.Y. 2013-14 because the ten-year limit under section 149 extended only up to A.Y. 2014-15. For A.Ys. 2014-15 to 2017-18, reopening beyond six years failed because the alleged escaped income was not represented as an asset, so jurisdiction was lacking. For A.Ys. 2018-19 to 2020-21, the notices were invalid since the income alleged did not satisfy the statutory conditions for reopening beyond three years under section 149(1)(b). The Tribunal also reduced the gross profit rate on unaccounted sales to 10% for A.Y. 2021-22, held the post-search assessment for A.Y. 2022-23 invalid for want of section 148/148B procedure, and deleted the section 41(1) addition for A.Y. 2023-24 as no cessation of liability was shown.
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