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...
Reopening of assessment u/s 147 was invalid as there was no failure by the assessee to disclose material facts. The assessment was reopened solely based on information that some parties from whom the assessee made purchases were non-filers of GST. However, the purchases were already examined and accepted in the original assessment order u/s 143(3). The Appellate Tribunal held that there was no document or evidence revealing any income chargeable to tax that had escaped assessment. Since the time limit for reopening had expired and the first proviso to Section 147 was not satisfied, the reopening itself was bad in law and quashed. The assessment order was quashed, and the assessee's appeal was allowed.
Reopening of assessment u/s 147 was invalid as there was no failure by the assessee to disclose material facts. The assessment was reopened solely based on information that some parties from whom the assessee made purchases were non-filers of GST. However, the purchases were already examined and accepted in the original assessment order u/s 143(3). The Appellate Tribunal held that there was no document or evidence revealing any income chargeable to tax that had escaped assessment. Since the time limit for reopening had expired and the first proviso to Section 147 was not satisfied, the reopening itself was bad in law and quashed. The assessment order was quashed, and the assessee's appeal was allowed.
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TaxTMI 
TaxTMI 
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