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 u/s 147 - The full and true disclosure of the assessee is not in doubt - The ‘recording of reasons’ is mechanical and robotic and the mandate u/s 147 has not been complied with - It was incumbent upon the AO to have had independent ‘reasons to believe’ that there is escapement of tax, even if the initial nudge did emanate from the audit department - reassessment quashed
Reassessment u/s 147 - The full and true disclosure of the assessee is not in doubt - The ‘recording of reasons’ is mechanical and robotic and the mandate u/s 147 has not been complied with - It was incumbent upon the AO to have had independent ‘reasons to believe’ that there is escapement of tax, even if the initial nudge did emanate from the audit department - reassessment quashed
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
