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 - Notice after the expiry of period of four years - Admissibility of deduction u/s 80I - The issue was already considered by the AO - In our view, the exercise to reopen a validly framed assessment is merely on the basis of change of opinion by succeeding Assessing Officer and such a mere change of opinion cannot justify the exercise of jurisdiction under Section 148. - HC
Reopening of assessment u/s 147 - Notice after the expiry of period of four years - Admissibility of deduction u/s 80I - The issue was already considered by the AO - In our view, the exercise to reopen a validly framed assessment is merely on the basis of change of opinion by succeeding Assessing Officer and such a mere change of opinion cannot justify the exercise of jurisdiction under Section 148. - HC
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TaxTMI 
TaxTMI 
of 4918 
