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 proceedings initiated under s.147 due to procedural deficiencies and lack of specific information. AO failed to provide essential details including bank name in s.148A(b) notice, making it impossible for assessee to respond effectively. Despite assessee's objections and proof of closed ICICI account, AO proceeded hastily without proper verification. Department's failure to deny bank's confirmation of account closure and inability to establish prima facie connection between disputed account and assessee demonstrated non-compliance with s.148A procedural requirements. Court found reassessment notice invalid due to vague information, rushed decision-making, and department's failure to substantiate claims even during proceedings.
HC quashed reassessment proceedings initiated under s.147 due to procedural deficiencies and lack of specific information. AO failed to provide essential details including bank name in s.148A(b) notice, making it impossible for assessee to respond effectively. Despite assessee's objections and proof of closed ICICI account, AO proceeded hastily without proper verification. Department's failure to deny bank's confirmation of account closure and inability to establish prima facie connection between disputed account and assessee demonstrated non-compliance with s.148A procedural requirements. Court found reassessment notice invalid due to vague information, rushed decision-making, and department's failure to substantiate claims even during proceedings.
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