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 search and seizure u/s 132 - The Bombay High Court quashed the search and seizure actions conducted by the Income Tax Department u/s 132 of the Income Tax Act, 1961. The court found that the authorization for the search was based on unverified and irrelevant information, failing to meet the statutory requirements. Procedural safeguards outlined in section 132 were not observed, rendering the search illegal. The court emphasized the importance of adhering to procedural requirements to ensure the legitimacy of such invasive actions. Despite invalidating the search, the court allowed the revenue to use any information obtained during the search in subsequent proceedings.
Validity of search and seizure u/s 132 - The Bombay High Court quashed the search and seizure actions conducted by the Income Tax Department u/s 132 of the Income Tax Act, 1961. The court found that the authorization for the search was based on unverified and irrelevant information, failing to meet the statutory requirements. Procedural safeguards outlined in section 132 were not observed, rendering the search illegal. The court emphasized the importance of adhering to procedural requirements to ensure the legitimacy of such invasive actions. Despite invalidating the search, the court allowed the revenue to use any information obtained during the search in subsequent proceedings.
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TaxTMI 
TaxTMI 
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