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...
Revision u/s 263 - Suo moto revisional proceeding initiated - The Gauhati High Court allowed the writ petition and set aside the Show Cause Notice and the ex-parte Order issued u/s 263 for the assessment year 2017-18. The Court concluded that the initiation of proceedings was illegal, arbitrary, and without jurisdiction. The assessment order, even if erroneous, was not prejudicial to the revenue, as the discrepancy in long-term capital gains was related to exempt income. The judgment reaffirmed the necessity of both conditions being met for the exercise of revisional jurisdiction and emphasized adherence to principles of natural justice.
Revision u/s 263 - Suo moto revisional proceeding initiated - The Gauhati High Court allowed the writ petition and set aside the Show Cause Notice and the ex-parte Order issued u/s 263 for the assessment year 2017-18. The Court concluded that the initiation of proceedings was illegal, arbitrary, and without jurisdiction. The assessment order, even if erroneous, was not prejudicial to the revenue, as the discrepancy in long-term capital gains was related to exempt income. The judgment reaffirmed the necessity of both conditions being met for the exercise of revisional jurisdiction and emphasized adherence to principles of natural justice.
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TaxTMI 
TaxTMI 
of 4918 
