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...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
The HC quashed the reassessment notice issued under section 148 after expiry of four years, finding no valid "reason to believe" to reopen the assessment. The Court noted that the assessee had properly paid taxes under section 115JB, disclosed book profits, and had previously provided all requested information regarding cash credits and sundry creditors during the original assessment proceedings. The AO had examined these specific issues and completed assessment under section 143(3) after being satisfied with the information furnished. Having already scrutinized these matters during regular assessment, the AO lacked jurisdiction to reopen the same issues, rendering the impugned notice and subsequent proceedings unsustainable.
The HC quashed the reassessment notice issued under section 148 after expiry of four years, finding no valid "reason to believe" to reopen the assessment. The Court noted that the assessee had properly paid taxes under section 115JB, disclosed book profits, and had previously provided all requested information regarding cash credits and sundry creditors during the original assessment proceedings. The AO had examined these specific issues and completed assessment under section 143(3) after being satisfied with the information furnished. Having already scrutinized these matters during regular assessment, the AO lacked jurisdiction to reopen the same issues, rendering the impugned notice and subsequent proceedings unsustainable.
Note: It is a system-generated summary and is for quick reference only.
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