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...
The appeal is admitted on substantial questions of law regarding the jurisdiction of the Assessing Officer to complete the assessment after the expiry of 30 days from the date of notice u/s 142(1) of the Act. The questions pertain to whether the Tribunal was justified in quashing the assessment order despite the assessee's participation in the proceedings without raising the jurisdictional issue within the time limit u/s 124(3)(a), and whether the Tribunal's order is perverse for ignoring the ratio laid down in DCIT (Exemption) Vs. Kalinga Institute of Industrial Technology, wherein Section 124(3) precludes the assessee from questioning the AO's jurisdiction if not invoked within the specified time frame. The appellant is directed to file requisite documents, and service of notice on the respondent's advocates is waived.
The appeal is admitted on substantial questions of law regarding the jurisdiction of the Assessing Officer to complete the assessment after the expiry of 30 days from the date of notice u/s 142(1) of the Act. The questions pertain to whether the Tribunal was justified in quashing the assessment order despite the assessee's participation in the proceedings without raising the jurisdictional issue within the time limit u/s 124(3)(a), and whether the Tribunal's order is perverse for ignoring the ratio laid down in DCIT (Exemption) Vs. Kalinga Institute of Industrial Technology, wherein Section 124(3) precludes the assessee from questioning the AO's jurisdiction if not invoked within the specified time frame. The appellant is directed to file requisite documents, and service of notice on the respondent's advocates is waived.
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TaxTMI 
TaxTMI 
of 4918 
