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 Assessment u/s 153A - no search conducted u/s 132 and 132A as against the petitioner - Incriminating material from laptop - Electronic evidence admissibility - The High court concluded that the proceedings initiated u/s 153A, including the assessment order and demand notice based on the flawed panchnama and unauthorized search, were without jurisdiction and authority. Consequently, the court quashed the notice, assessment order, and demand notice, declaring the proceedings non-est and void ab initio.
Validity of Assessment u/s 153A - no search conducted u/s 132 and 132A as against the petitioner - Incriminating material from laptop - Electronic evidence admissibility - The High court concluded that the proceedings initiated u/s 153A, including the assessment order and demand notice based on the flawed panchnama and unauthorized search, were without jurisdiction and authority. Consequently, the court quashed the notice, assessment order, and demand notice, declaring the proceedings non-est and void ab initio.
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