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...
Reassessment initiated after four years from the end of the assessment year was held invalid where the original assessment had been completed under scrutiny and the recorded reasons showed that the information on alleged accommodation entries was already available during that assessment. In the absence of any allegation in the reasons that the assessee had failed to disclose fully and truly all material facts, the jurisdictional requirement for reopening beyond four years was not met. The notice under section 148 and the consequential reassessment order were quashed, and the merits of the additions were left unexamined.
Reassessment initiated after four years from the end of the assessment year was held invalid where the original assessment had been completed under scrutiny and the recorded reasons showed that the information on alleged accommodation entries was already available during that assessment. In the absence of any allegation in the reasons that the assessee had failed to disclose fully and truly all material facts, the jurisdictional requirement for reopening beyond four years was not met. The notice under section 148 and the consequential reassessment order were quashed, and the merits of the additions were left unexamined.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
