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...
The High Court revisited the reopening of assessment u/s 147 due to the assessee's involvement in penny share transactions. The petitioner invested in shares through IPO and provided necessary details during regular assessment. The Assessing Officer relied on information from DDIT Investigation Unit to allege income escapement. However, the Court found that the AO lacked independent application of mind, as the reasons recorded did not establish a direct connection between the information and the transactions. Consequently, the jurisdiction was deemed based on borrowed satisfaction, leading to a decision in favor of the assessee.
The High Court revisited the reopening of assessment u/s 147 due to the assessee's involvement in penny share transactions. The petitioner invested in shares through IPO and provided necessary details during regular assessment. The Assessing Officer relied on information from DDIT Investigation Unit to allege income escapement. However, the Court found that the AO lacked independent application of mind, as the reasons recorded did not establish a direct connection between the information and the transactions. Consequently, the jurisdiction was deemed based on borrowed satisfaction, leading to a decision in favor of the assessee.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
