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...
Block assessment - Validity of assessment u/s 158BC r.w.s. 158BD - The High court allowed the appeal, holding that the assessment proceedings were illegal due to the failure of the assessing officer to record satisfaction as required under Section 158BD of the Income Tax Act. The appellant provided sufficient evidence to support the ownership claim of the seized cash, and the assessing officer's doubts were deemed unjustified.
Block assessment - Validity of assessment u/s 158BC r.w.s. 158BD - The High court allowed the appeal, holding that the assessment proceedings were illegal due to the failure of the assessing officer to record satisfaction as required under Section 158BD of the Income Tax Act. The appellant provided sufficient evidence to support the ownership claim of the seized cash, and the assessing officer's doubts were deemed unjustified.
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