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 the order passed u/s 148A(d) - Reopening of assessment - In exercise of jurisdiction under Article 226 of the Constitution of India, once this Court finds that the impugned order does not suffer from any procedural error and the same has been passed after giving an opportunity of hearing, it is advisable to restrain from interfering in the matter and left it open for the petitioner to raise all the grounds as raised in this petition to explain the transaction regarding issuance of shares in the assessment proceedings. - HC
Validity of the order passed u/s 148A(d) - Reopening of assessment - In exercise of jurisdiction under Article 226 of the Constitution of India, once this Court finds that the impugned order does not suffer from any procedural error and the same has been passed after giving an opportunity of hearing, it is advisable to restrain from interfering in the matter and left it open for the petitioner to raise all the grounds as raised in this petition to explain the transaction regarding issuance of shares in the assessment proceedings. - HC
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TaxTMI 
TaxTMI 
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