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...
ITAT set aside Pr.CIT's order under section 263, finding procedural irregularities in reassessment proceedings. The tribunal determined that Pr.CIT exceeded jurisdictional limits by: (1) considering documents not available during original examination, (2) introducing issues beyond the original reassessment scope under section 147, and (3) improperly evaluating additional tax-related matters not part of initial proceedings. The tribunal emphasized that revisional powers must be exercised strictly based on records existing at the time of original assessment. Consequently, the entire proceedings were deemed ultra vires, with the appellate order partially allowing the assessee's appeal and nullifying the CIT's interventions.
ITAT set aside Pr.CIT's order under section 263, finding procedural irregularities in reassessment proceedings. The tribunal determined that Pr.CIT exceeded jurisdictional limits by: (1) considering documents not available during original examination, (2) introducing issues beyond the original reassessment scope under section 147, and (3) improperly evaluating additional tax-related matters not part of initial proceedings. The tribunal emphasized that revisional powers must be exercised strictly based on records existing at the time of original assessment. Consequently, the entire proceedings were deemed ultra vires, with the appellate order partially allowing the assessee's appeal and nullifying the CIT's interventions.
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TaxTMI 
TaxTMI 
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