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...
Reassessment proceedings initiated beyond statutory time limit prescribed under pre-amended Section 149(1)(b) quashed. Notice u/s 148 issued after expiry of six-year period from end of relevant assessment year held impermissible. Statutory time limit not extendable through judicial interpretation or by invoking other provisions. Writ petition allowed, impugned order u/s 148A(d) and consequential notice u/s 148 quashed.
Reassessment proceedings initiated beyond statutory time limit prescribed under pre-amended Section 149(1)(b) quashed. Notice u/s 148 issued after expiry of six-year period from end of relevant assessment year held impermissible. Statutory time limit not extendable through judicial interpretation or by invoking other provisions. Writ petition allowed, impugned order u/s 148A(d) and consequential notice u/s 148 quashed.
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TaxTMI 
TaxTMI 
of 4918 
