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...
Lack of jurisdiction of AO in issuing notice u/s.143 (2) - Change of residential address of the assessee - The Appellate Tribunal admitted the additional ground raised by the appellant, citing relevant legal precedents. They emphasized that the additional ground related to the jurisdiction of the AO and was crucial to the assessment proceedings. - After considering the arguments from both parties and relevant legal principles, the Tribunal found that the notice under Section 143(2) issued by the AO in Delhi lacked jurisdiction since the appellant's residence was in Gurgaon. The Tribunal held that the issuance of notice by an AO lacking jurisdiction rendered the assessment proceedings invalid.
Lack of jurisdiction of AO in issuing notice u/s.143 (2) - Change of residential address of the assessee - The Appellate Tribunal admitted the additional ground raised by the appellant, citing relevant legal precedents. They emphasized that the additional ground related to the jurisdiction of the AO and was crucial to the assessment proceedings. - After considering the arguments from both parties and relevant legal principles, the Tribunal found that the notice under Section 143(2) issued by the AO in Delhi lacked jurisdiction since the appellant's residence was in Gurgaon. The Tribunal held that the issuance of notice by an AO lacking jurisdiction rendered the assessment proceedings invalid.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
