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 HC held that the AO lacked jurisdiction to reopen the assessment beyond four years u/s 147. The reasons did not establish the assessee's failure to fully disclose material facts. The AO merely changed its opinion on the same material, which is impermissible. Reopening was based on existing material without any fresh tangible evidence, violating the first proviso to Section 147. The HC entertained the writ petition and quashed the reopening notice for lack of jurisdictional compliance.
The HC held that the AO lacked jurisdiction to reopen the assessment beyond four years u/s 147. The reasons did not establish the assessee's failure to fully disclose material facts. The AO merely changed its opinion on the same material, which is impermissible. Reopening was based on existing material without any fresh tangible evidence, violating the first proviso to Section 147. The HC entertained the writ petition and quashed the reopening notice for lack of jurisdictional compliance.
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TaxTMI 
TaxTMI 
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