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 Reassessment proceedings - notice u/s. 148A(b) issued in the name of a dead assessee - The High court acknowledges that the petitioner failed to inform the department about the death of the original assessee and did not produce the death certificate. It notes that the assessment proceedings have concluded, and the final assessment order has been passed. - The court emphasizes that when a statutory remedy is available, a writ petition cannot be entertained except in exceptional circumstances. It holds that since the proceedings under Section 148 have attained finality, it is inappropriate to entertain the writ petition at this stage. - The court dismisses the petition with liberty to the petitioner to take recourse to the statutory remedy of appeal.
Validity of Reassessment proceedings - notice u/s. 148A(b) issued in the name of a dead assessee - The High court acknowledges that the petitioner failed to inform the department about the death of the original assessee and did not produce the death certificate. It notes that the assessment proceedings have concluded, and the final assessment order has been passed. - The court emphasizes that when a statutory remedy is available, a writ petition cannot be entertained except in exceptional circumstances. It holds that since the proceedings under Section 148 have attained finality, it is inappropriate to entertain the writ petition at this stage. - The court dismisses the petition with liberty to the petitioner to take recourse to the statutory remedy of appeal.
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TaxTMI 
TaxTMI 
of 4918 
