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 Appellate Tribunal (ITAT) addressed the validity of an assessment order passed u/s 153C, considering the issue of limitation. The assessee raised the plea that the assessment year 2004-05 was beyond the six-year block period for assessment u/s 153C. Although the order bore the date 30.12.2011, it was issued and dispatched on 02.01.2012 as per the post office report. Since the assessee raised this plea for the first time during the appeal hearing, the ITAT remanded the issue to the Assessing Officer for proper verification and adjudication, along with other set-aside issues. The appeal was allowed for statistical purposes.
The Appellate Tribunal (ITAT) addressed the validity of an assessment order passed u/s 153C, considering the issue of limitation. The assessee raised the plea that the assessment year 2004-05 was beyond the six-year block period for assessment u/s 153C. Although the order bore the date 30.12.2011, it was issued and dispatched on 02.01.2012 as per the post office report. Since the assessee raised this plea for the first time during the appeal hearing, the ITAT remanded the issue to the Assessing Officer for proper verification and adjudication, along with other set-aside issues. The appeal was allowed for statistical purposes.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
