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...
Reopening of assessment u/s 147 - Validity of reason to believe - notice not in the name of assessee but issued in the name of minor daughter - The right course under the law should have been that the assessee's case, should have been reopened and notice u/s. 148, should have been issued in the name of Father and if there is any undisclosed income belonging to the minor, and a different PAN cannot validate the proceedings - AT
Reopening of assessment u/s 147 - Validity of reason to believe - notice not in the name of assessee but issued in the name of minor daughter - The right course under the law should have been that the assessee's case, should have been reopened and notice u/s. 148, should have been issued in the name of Father and if there is any undisclosed income belonging to the minor, and a different PAN cannot validate the proceedings - AT
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