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 reopening of assessment u/s 147 - if the appellant is to be relegated to pursue the appellate remedy, all such findings needs to be vacated, otherwise it would tantamount to putting fetters on the exercise of the powers of the appellate remedy which should not be done. Thus, all issues are left open and the appellant is at liberty to canvas all factual and legal issues before the First Appellate Authority which shall be considered and decided by the First Appellate Authority in accordance with law. - HC
Validity of reopening of assessment u/s 147 - if the appellant is to be relegated to pursue the appellate remedy, all such findings needs to be vacated, otherwise it would tantamount to putting fetters on the exercise of the powers of the appellate remedy which should not be done. Thus, all issues are left open and the appellant is at liberty to canvas all factual and legal issues before the First Appellate Authority which shall be considered and decided by the First Appellate Authority in accordance with law. - HC
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TaxTMI 
TaxTMI 
of 4918 
