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 approval u/s 153D was mechanically granted without proper application of mind, violating principles of natural justice. The sanctioning authority failed to ensure complete documentation and opportunity of hearing for the assessee regarding a valuer's report. Consequently, the approval was deemed invalid, rendering the consequential assessment void ab initio. The tribunal quashed the assessment proceedings due to non-satisfaction of statutory mandates, ultimately allowing the assessee's appeal and invalidating the entire assessment process.
ITAT held that the approval u/s 153D was mechanically granted without proper application of mind, violating principles of natural justice. The sanctioning authority failed to ensure complete documentation and opportunity of hearing for the assessee regarding a valuer's report. Consequently, the approval was deemed invalid, rendering the consequential assessment void ab initio. The tribunal quashed the assessment proceedings due to non-satisfaction of statutory mandates, ultimately allowing the assessee's appeal and invalidating the entire assessment process.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
