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 ITAT held that initiation of proceedings u/s 153C requires the Assessing Officer to obtain a certificate verifying the veracity and reliability of the record. In the absence of such compliance and a certificate u/s 65B of the Evidence Act, 1872, which is mandatory, the action of the Assessing Officer to initiate proceedings u/s 153C was improper. Accordingly, the relevant ground raised by the assessee was allowed.
The ITAT held that initiation of proceedings u/s 153C requires the Assessing Officer to obtain a certificate verifying the veracity and reliability of the record. In the absence of such compliance and a certificate u/s 65B of the Evidence Act, 1872, which is mandatory, the action of the Assessing Officer to initiate proceedings u/s 153C was improper. Accordingly, the relevant ground raised by the assessee was allowed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
