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...
Validity of assessment u/s 144 r.w.s. 144B - As argued assessment order is an exact reproduction of the draft assessment order except one sentence which has been added “Regarding this show cause notice issued to assessee on 22.04.2021 but assessee has not given any justification for non-furnishing of quantitative details in form 3CD" - We wonder how does the affiant know something which the assessment order does not reflect. - There cannot be anything far from truth. - We are, therefore, compelled to set aside the order - HC
Validity of assessment u/s 144 r.w.s. 144B - As argued assessment order is an exact reproduction of the draft assessment order except one sentence which has been added “Regarding this show cause notice issued to assessee on 22.04.2021 but assessee has not given any justification for non-furnishing of quantitative details in form 3CD" - We wonder how does the affiant know something which the assessment order does not reflect. - There cannot be anything far from truth. - We are, therefore, compelled to set aside the order - HC
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TaxTMI 
TaxTMI 
of 4918 
