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...
HC quashed reassessment notices and order finding them invalid under Section 147 of Income Tax Act. Notices issued after four years were without fresh material indicating escaped income. Complete disclosure was made in original return and assessment under Section 143(3). AO's attempt to revisit Section 14A disallowance constituted mere change of opinion, not valid grounds for reopening. Court emphasized that determining Section 14A disallowance was AO's responsibility during original assessment, where assessee had provided all relevant documents. Reopening failed first proviso requirements of Section 147, particularly beyond four-year limitation period. Jurisdiction could not be assumed without failure by assessee to disclose material facts.
HC quashed reassessment notices and order finding them invalid under Section 147 of Income Tax Act. Notices issued after four years were without fresh material indicating escaped income. Complete disclosure was made in original return and assessment under Section 143(3). AO's attempt to revisit Section 14A disallowance constituted mere change of opinion, not valid grounds for reopening. Court emphasized that determining Section 14A disallowance was AO's responsibility during original assessment, where assessee had provided all relevant documents. Reopening failed first proviso requirements of Section 147, particularly beyond four-year limitation period. Jurisdiction could not be assumed without failure by assessee to disclose material facts.
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