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...
Validity of the reassessment order u/s 147 - addition of bogus accommodation entry - AO has not even mentioned as to what was the nature of entry as given in the report and simply saying that assessee received entry (of huge amount) from entry operators during the period is not sufficient. Such a vague reasons cannot justify the reopening and as observed above, the Assessing Officer can validly acquire jurisdiction only when the reasons recorded itself points out or speaks of live link nexus with the material available on record and income escaping assessment and it should not be vague or mere pretence - the reasons recorded does not confer any jurisdiction to him reopen the case - AT
Validity of the reassessment order u/s 147 - addition of bogus accommodation entry - AO has not even mentioned as to what was the nature of entry as given in the report and simply saying that assessee received entry (of huge amount) from entry operators during the period is not sufficient. Such a vague reasons cannot justify the reopening and as observed above, the Assessing Officer can validly acquire jurisdiction only when the reasons recorded itself points out or speaks of live link nexus with the material available on record and income escaping assessment and it should not be vague or mere pretence - the reasons recorded does not confer any jurisdiction to him reopen the case - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
