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...
Draft assessment repeated in the final order without incorporating DRP directions was held invalid, because directions under section 144C bind the Assessing Officer and the final assessment must conform to them. The Tribunal, following Olympus Medical Systems (P) Ltd., treated non-conformity with the DRP procedure as rendering the final assessment order bad in law and liable to be quashed. On that basis, the impugned order was quashed as null and void, and the remaining jurisdictional and merits grounds were left unadjudicated.
Draft assessment repeated in the final order without incorporating DRP directions was held invalid, because directions under section 144C bind the Assessing Officer and the final assessment must conform to them. The Tribunal, following Olympus Medical Systems (P) Ltd., treated non-conformity with the DRP procedure as rendering the final assessment order bad in law and liable to be quashed. On that basis, the impugned order was quashed as null and void, and the remaining jurisdictional and merits grounds were left unadjudicated.
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TaxTMI 
TaxTMI 
of 4918 
