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...
Revisional jurisdiction under section 263 was not available where the assessment in limited scrutiny was completed after the assessee disclosed the survey declaration and responded to section 142(1) notices, and the Assessing Officer considered those materials. Applying Malabar Industrial and Arvind Jewellers, revision lies only when the assessment order is both erroneous and prejudicial to the interests of the Revenue; a mere difference of opinion on the same material is insufficient. On the facts found, no such error was shown, so the Tribunal was right to quash the revisional order and no substantial question of law arose.
Revisional jurisdiction under section 263 was not available where the assessment in limited scrutiny was completed after the assessee disclosed the survey declaration and responded to section 142(1) notices, and the Assessing Officer considered those materials. Applying Malabar Industrial and Arvind Jewellers, revision lies only when the assessment order is both erroneous and prejudicial to the interests of the Revenue; a mere difference of opinion on the same material is insufficient. On the facts found, no such error was shown, so the Tribunal was right to quash the revisional order and no substantial question of law arose.
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TaxTMI 
TaxTMI 
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