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 - requirement of giving minimum of 7 days notice - While redoing the exercise, it is open to the respondent to issue a notice afresh u/s 148B giving not less than 7 days to the petitioner/assessee to respond and on receipt of the same, the petitioner shall respond by giving their reply or inputs within the time stipulated therein. - HC
Reopening of assessment u/s 147 - requirement of giving minimum of 7 days notice - While redoing the exercise, it is open to the respondent to issue a notice afresh u/s 148B giving not less than 7 days to the petitioner/assessee to respond and on receipt of the same, the petitioner shall respond by giving their reply or inputs within the time stipulated therein. - HC
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