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...
Fair and effective opportunity of hearing in faceless reassessment requires communications to reach the assessee through its notified or registered contact details. The High Court noted that the assessee had provided an email address in its return and had another registered on the income-tax portal and MCA database, but subsequent notices were sent only to a resigned auditor's email address. As this prevented an adequate response with supporting material, the assessment order and demand notice were quashed and remanded for fresh proceedings, including a response opportunity, video-conference hearing and speaking order. The merits and validity of service under Rule 127 were left open.
Fair and effective opportunity of hearing in faceless reassessment requires communications to reach the assessee through its notified or registered contact details. The High Court noted that the assessee had provided an email address in its return and had another registered on the income-tax portal and MCA database, but subsequent notices were sent only to a resigned auditor's email address. As this prevented an adequate response with supporting material, the assessment order and demand notice were quashed and remanded for fresh proceedings, including a response opportunity, video-conference hearing and speaking order. The merits and validity of service under Rule 127 were left open.
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