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 upheld CIT(A)'s decision that assessment order under s.143(3) r.w.s. 144C(3) r.w.s. 144B was time-barred. TPO reference under s.92CA(1) was made on 13.09.2021, with TPO order under s.92CA(3) issued on 28.01.2022. Per s.153(4), deadline extended to 31.03.2022, but assessment order was passed on 30.09.2022, beyond statutory limitation period. Without CBDT extension or statutory provision extending timeline, assessment order was invalid. Jurisdictional issue of limitation decided against Revenue, confirming assessment as time-barred.
ITAT upheld CIT(A)'s decision that assessment order under s.143(3) r.w.s. 144C(3) r.w.s. 144B was time-barred. TPO reference under s.92CA(1) was made on 13.09.2021, with TPO order under s.92CA(3) issued on 28.01.2022. Per s.153(4), deadline extended to 31.03.2022, but assessment order was passed on 30.09.2022, beyond statutory limitation period. Without CBDT extension or statutory provision extending timeline, assessment order was invalid. Jurisdictional issue of limitation decided against Revenue, confirming assessment as time-barred.
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