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 held that the notice u/s 148 of the Income Tax Act issued on April 4, 2022, was beyond the prescribed period of limitation, rendering the consequent actions illegal. Mere issuance of a notice u/s 148A for conducting an inquiry before issuing a notice u/s 148 cannot be read within the ambit of the first proviso to Section 149(1). Additionally, the notice issued on August 27, 2022, by the Joint Assessing Officer (JAO) fell outside the faceless assessment scheme u/s 151A, as it was not issued by the National Faceless Assessment Centre as required under the scheme. Consequently, the assessee's appeal was allowed.
The High Court held that the notice u/s 148 of the Income Tax Act issued on April 4, 2022, was beyond the prescribed period of limitation, rendering the consequent actions illegal. Mere issuance of a notice u/s 148A for conducting an inquiry before issuing a notice u/s 148 cannot be read within the ambit of the first proviso to Section 149(1). Additionally, the notice issued on August 27, 2022, by the Joint Assessing Officer (JAO) fell outside the faceless assessment scheme u/s 151A, as it was not issued by the National Faceless Assessment Centre as required under the scheme. Consequently, the assessee's appeal was allowed.
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