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 Faceless assessment of income escaping assessment u/s 151 - According to Petitioners, the notice could have been issued only by the Faceless Assessing Officer (“FAO”) not issued by the Jurisdictional Assessing Officer (“JAO”) - The court acknowledged that the issues in the present petitions were covered by the Hexaware Technologies judgment and consequently quashed the impugned notices. Any reassessment orders, demand notices, or penalties based on these invalid notices were also set aside. The court extended this benefit to petitioners who had raised the issue of notice validity orally and disposed of the petitions and any pending interim applications accordingly.
Validity of Faceless assessment of income escaping assessment u/s 151 - According to Petitioners, the notice could have been issued only by the Faceless Assessing Officer (“FAO”) not issued by the Jurisdictional Assessing Officer (“JAO”) - The court acknowledged that the issues in the present petitions were covered by the Hexaware Technologies judgment and consequently quashed the impugned notices. Any reassessment orders, demand notices, or penalties based on these invalid notices were also set aside. The court extended this benefit to petitioners who had raised the issue of notice validity orally and disposed of the petitions and any pending interim applications accordingly.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
