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 invalidated reassessment proceedings under s.147 for AY 2014-15 initiated beyond four years. AO failed to demonstrate any failure by assessee to fully disclose material facts necessary for assessment. Reopening was based on existing records already furnished during original assessment. No fresh tangible material existed to form independent opinion for reopening. Mandatory procedures under s.144B were violated as objections to reopening notice were not addressed. AO passed final order within one day of receiving assessee's reply to draft assessment order without providing reasonable opportunity of hearing. Order declared void for violating natural justice principles and jurisdictional requirements under first proviso to s.147.
HC invalidated reassessment proceedings under s.147 for AY 2014-15 initiated beyond four years. AO failed to demonstrate any failure by assessee to fully disclose material facts necessary for assessment. Reopening was based on existing records already furnished during original assessment. No fresh tangible material existed to form independent opinion for reopening. Mandatory procedures under s.144B were violated as objections to reopening notice were not addressed. AO passed final order within one day of receiving assessee's reply to draft assessment order without providing reasonable opportunity of hearing. Order declared void for violating natural justice principles and jurisdictional requirements under first proviso to s.147.
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