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...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
Validity of reopening of assessment u/s 147 - Purchase the immovable property on which TDS has been deducted - TDS statement (Form 26QB) shows the amount of purchase of property twice - The notice to the petitioner has been based only for the aforesaid reasons, whereas the impugned order would further add new reasons for the order. The petitioner had not been given an opportunity to answer and explain the same. - Proceedings set aside - Petitioner / assessee allowed to submit the reply and opportunity of personal hearing shall be given to the assessee - HC
Validity of reopening of assessment u/s 147 - Purchase the immovable property on which TDS has been deducted - TDS statement (Form 26QB) shows the amount of purchase of property twice - The notice to the petitioner has been based only for the aforesaid reasons, whereas the impugned order would further add new reasons for the order. The petitioner had not been given an opportunity to answer and explain the same. - Proceedings set aside - Petitioner / assessee allowed to submit the reply and opportunity of personal hearing shall be given to the assessee - HC
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4921 
