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 draft assessment order u/s 144C(1) - difference in numbers in closing and opening stock of Lingerie - The show cause notice lacked specific quantification of proposed additions to income - The High court directed that the draft assessment order be treated as a show cause notice, allowing the petitioner to submit a reply within three weeks. The assessing officer was instructed to provide a reasonable opportunity, including a personal hearing through video conferencing, before issuing a fresh draft assessment order.
Validity of draft assessment order u/s 144C(1) - difference in numbers in closing and opening stock of Lingerie - The show cause notice lacked specific quantification of proposed additions to income - The High court directed that the draft assessment order be treated as a show cause notice, allowing the petitioner to submit a reply within three weeks. The assessing officer was instructed to provide a reasonable opportunity, including a personal hearing through video conferencing, before issuing a fresh draft assessment order.
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