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...
ITAT determined assessment order under sections 263/143(3)/147 was time-barred and invalid. Though AO passed order on 30.12.2015, it was served to assessee on 05.01.2016, beyond statutory deadline of 31.12.2015 per Section 153. AO's subsequent clarification citing 30.12.2015 as order date conflicted with claimed execution date of 31.12.2015. Despite intervening weekend holidays, failure to serve within limitation period rendered order non-est and void ab initio. Tribunal upheld assessee's appeal, declaring assessment proceedings legally invalid due to service beyond prescribed limitation period.
ITAT determined assessment order under sections 263/143(3)/147 was time-barred and invalid. Though AO passed order on 30.12.2015, it was served to assessee on 05.01.2016, beyond statutory deadline of 31.12.2015 per Section 153. AO's subsequent clarification citing 30.12.2015 as order date conflicted with claimed execution date of 31.12.2015. Despite intervening weekend holidays, failure to serve within limitation period rendered order non-est and void ab initio. Tribunal upheld assessee's appeal, declaring assessment proceedings legally invalid due to service beyond prescribed limitation period.
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TaxTMI 
TaxTMI 
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