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...
Transfer of jurisdiction from Faridabad to Delhi was held invalid because the assessee was not given a reasonable opportunity of being heard before the transfer order was made. Notices under section 143(2) issued by Delhi officers were therefore treated as without valid jurisdiction and ineffective for the assessment year concerned. After the transfer order was cancelled, jurisdiction reverted to the original Assessing Officer at Faridabad, but that officer also completed the assessment without first issuing a valid section 143(2) notice. The assessment was consequently quashed for a foundational jurisdictional defect, and the merits were left undecided.
Transfer of jurisdiction from Faridabad to Delhi was held invalid because the assessee was not given a reasonable opportunity of being heard before the transfer order was made. Notices under section 143(2) issued by Delhi officers were therefore treated as without valid jurisdiction and ineffective for the assessment year concerned. After the transfer order was cancelled, jurisdiction reverted to the original Assessing Officer at Faridabad, but that officer also completed the assessment without first issuing a valid section 143(2) notice. The assessment was consequently quashed for a foundational jurisdictional defect, and the merits were left undecided.
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TaxTMI 
TaxTMI 
of 4918 
