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 HC allowed the petition and set aside the impugned reassessment notice and subsequent proceedings. The AO's satisfaction note for invoking reassessment proceedings u/s 153C of the Income Tax Act was held to be barred by limitation, as it was prepared beyond the prescribed 10-year period from the relevant assessment year. The HC concluded that the notice was invalid and quashed the reassessment proceedings initiated against the petitioner.
The HC allowed the petition and set aside the impugned reassessment notice and subsequent proceedings. The AO's satisfaction note for invoking reassessment proceedings u/s 153C of the Income Tax Act was held to be barred by limitation, as it was prepared beyond the prescribed 10-year period from the relevant assessment year. The HC concluded that the notice was invalid and quashed the reassessment proceedings initiated against the petitioner.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
