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 - Re-opening is on the basis of gross incorrect facts that the assessment had been completed u/s 143(1) of the Act of 1961 and was hence no assessment u/s 2(40) of the Act of 1961 when infact the assessment had been completed u/s 143(3) - re-opening was thus merely an outcome of change of opinion of the AO - HC
Reopening of assessment - Re-opening is on the basis of gross incorrect facts that the assessment had been completed u/s 143(1) of the Act of 1961 and was hence no assessment u/s 2(40) of the Act of 1961 when infact the assessment had been completed u/s 143(3) - re-opening was thus merely an outcome of change of opinion of the AO - HC
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TaxTMI 
TaxTMI 
of 4918 
