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 - reason to belief - Bogus share transactions - AO, while recording the reasons, has not applied his mind and has not brought out any factual finding with regard to the impugned addition. It is also noticed that the assessee’s request with regard to the workings of the impugned addition and the statements recorded from the Broker was not shared with him by the lower authorities - the reopening u/s. 147 is not valid and accordingly, the addition made stands deleted. - AT
Validity of Reopening of assessment - reason to belief - Bogus share transactions - AO, while recording the reasons, has not applied his mind and has not brought out any factual finding with regard to the impugned addition. It is also noticed that the assessee’s request with regard to the workings of the impugned addition and the statements recorded from the Broker was not shared with him by the lower authorities - the reopening u/s. 147 is not valid and accordingly, the addition made stands deleted. - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
