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...
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Assessment order u/s 147 read with Section 144B was challenged on grounds of violation of principles of natural justice as virtual hearing was not granted despite request and assessment order was passed within short notice. The Court held that granting only two days' time to respond to show cause notice and not providing opportunity for virtual hearing despite request constituted breach of principles of natural justice. Relying on precedent, the Court quashed the assessment order, consequential demand notice, and penalty notice, allowing the writ petition on these grounds.
Assessment order u/s 147 read with Section 144B was challenged on grounds of violation of principles of natural justice as virtual hearing was not granted despite request and assessment order was passed within short notice. The Court held that granting only two days' time to respond to show cause notice and not providing opportunity for virtual hearing despite request constituted breach of principles of natural justice. Relying on precedent, the Court quashed the assessment order, consequential demand notice, and penalty notice, allowing the writ petition on these grounds.
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