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 Reopening of assessment - acquisition of immovable property jointly - husband’s assessment in hands of wife - The court quashed and set aside the order dated 31st March 2023 passed under Section 148A(d) of the Act. The court concluded that it was not a suitable case for reopening the assessment concerning the petitioner. The court highlighted the lack of necessity in seeking details from the petitioner regarding the source of funds, given that it was established that she had no involvement in the transactions. Moreover, the court noted the surprising behavior of the Principal Chief Commissioner of Income Tax, who sanctioned the issuance of the order instead of directing the assessing officer to drop the proceedings against the petitioner.
Validity of Reopening of assessment - acquisition of immovable property jointly - husband’s assessment in hands of wife - The court quashed and set aside the order dated 31st March 2023 passed under Section 148A(d) of the Act. The court concluded that it was not a suitable case for reopening the assessment concerning the petitioner. The court highlighted the lack of necessity in seeking details from the petitioner regarding the source of funds, given that it was established that she had no involvement in the transactions. Moreover, the court noted the surprising behavior of the Principal Chief Commissioner of Income Tax, who sanctioned the issuance of the order instead of directing the assessing officer to drop the proceedings against the petitioner.
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