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 notice u/s 148 - “reason to believe" must be interpreted that the AO on receipt of any such new material or materials in relation to the non furnishing of fact by the assessee has made out a prima facie opinion that it is the case for reopening of the assessment - in the absence of having knowledge about the reasons, the petitioners cannot come to the conclusion that there is no new material or reason to reopen the assessment - writ dismissed
Reassessment notice u/s 148 - “reason to believe" must be interpreted that the AO on receipt of any such new material or materials in relation to the non furnishing of fact by the assessee has made out a prima facie opinion that it is the case for reopening of the assessment - in the absence of having knowledge about the reasons, the petitioners cannot come to the conclusion that there is no new material or reason to reopen the assessment - writ dismissed
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
