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 the validity of reopening assessment under Section 147, rejecting the assessee's challenge to the Section 148 notice. The Tribunal found that since no regular assessment under Section 143(3) had previously been conducted, with the return only processed under Section 143(1), the notice issued with JCIT's authority after four years was procedurally valid per Section 151(2). However, regarding cartage expenses, the ITAT partially allowed the appeal by restricting the disallowance to 15% of the expenses, consistent with the CIT(A)'s order for A.Y. 2011-12 which involved identical factual circumstances.
ITAT upheld the validity of reopening assessment under Section 147, rejecting the assessee's challenge to the Section 148 notice. The Tribunal found that since no regular assessment under Section 143(3) had previously been conducted, with the return only processed under Section 143(1), the notice issued with JCIT's authority after four years was procedurally valid per Section 151(2). However, regarding cartage expenses, the ITAT partially allowed the appeal by restricting the disallowance to 15% of the expenses, consistent with the CIT(A)'s order for A.Y. 2011-12 which involved identical factual circumstances.
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