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 held that the transfer pricing order dated 12.01.2015 merged into the final assessment order dated 20.04.2015 for AY 2011-12 was quashed by CIT(A) as being passed in a non-existent entity's name. Consequently, the extended 12-month time limit for passing the final assessment order was invalid. The assessment order dated 12.05.2015 was beyond the prescribed limitation period of 31.03.2015. The tribunal ruled that the impugned order under section 143(3) read with section 144C was time-barred and liable to be quashed, thereby allowing the assessee's challenge to the order's validity.
ITAT held that the transfer pricing order dated 12.01.2015 merged into the final assessment order dated 20.04.2015 for AY 2011-12 was quashed by CIT(A) as being passed in a non-existent entity's name. Consequently, the extended 12-month time limit for passing the final assessment order was invalid. The assessment order dated 12.05.2015 was beyond the prescribed limitation period of 31.03.2015. The tribunal ruled that the impugned order under section 143(3) read with section 144C was time-barred and liable to be quashed, thereby allowing the assessee's challenge to the order's validity.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
