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...
HC dismissed the writ appeal challenging reassessment proceedings under Section 147. The AO reopened the assessment based on a District Valuation Officer's report revealing discrepancies in construction expenditure and undisclosed income. The court found the reassessment valid, noting the Assessing Officer recorded legitimate reasons for believing income had escaped assessment. The appellant was afforded opportunity to raise defenses through appellate proceedings. Considering the fresh order passed by the Assessing Authority and alternative remedy under Section 246A, the intra-court appeal was rejected without interference, effectively decided against the assessee.
HC dismissed the writ appeal challenging reassessment proceedings under Section 147. The AO reopened the assessment based on a District Valuation Officer's report revealing discrepancies in construction expenditure and undisclosed income. The court found the reassessment valid, noting the Assessing Officer recorded legitimate reasons for believing income had escaped assessment. The appellant was afforded opportunity to raise defenses through appellate proceedings. Considering the fresh order passed by the Assessing Authority and alternative remedy under Section 246A, the intra-court appeal was rejected without interference, effectively decided against the assessee.
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