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...
ITAT held that the assessment order under old PAN cannot survive where the appellant company has already filed returns and been assessed under new PAN as a 'Company'. The tribunal condoned the delay in filing appeals, finding 'sufficient and reasonable cause' due to the company's unawareness of proceedings. The matter was remanded to the jurisdictional AO to verify transactions reported under the old PAN and confirm whether they were already accounted in the company's books of accounts. The duplicate PAN status was acknowledged, and no fresh assessment was deemed necessary.
ITAT held that the assessment order under old PAN cannot survive where the appellant company has already filed returns and been assessed under new PAN as a 'Company'. The tribunal condoned the delay in filing appeals, finding 'sufficient and reasonable cause' due to the company's unawareness of proceedings. The matter was remanded to the jurisdictional AO to verify transactions reported under the old PAN and confirm whether they were already accounted in the company's books of accounts. The duplicate PAN status was acknowledged, and no fresh assessment was deemed necessary.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
