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...
For a non-searched person, the relevant date for determining the block period and search year under section 153C is the date on which seized material is received by the Assessing Officer having jurisdiction over that person, not the date of search in the searched person's case. On that basis, an assessment for the search-related year must be made, if at all, under section 153C read with section 153A; framing it under section 143(3) is a fatal jurisdictional defect. The impugned assessment for Assessment Year 2017-18 was therefore treated as without jurisdiction.
For a non-searched person, the relevant date for determining the block period and search year under section 153C is the date on which seized material is received by the Assessing Officer having jurisdiction over that person, not the date of search in the searched person's case. On that basis, an assessment for the search-related year must be made, if at all, under section 153C read with section 153A; framing it under section 143(3) is a fatal jurisdictional defect. The impugned assessment for Assessment Year 2017-18 was therefore treated as without jurisdiction.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
