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 Order: Procedural Violation in Limited Scrutiny Assessment The ITAT held that the Assessing Officer (AO) exceeded jurisdictional limits by expanding the scope of 'limited scrutiny' without following mandatory procedural requirements. The AO improperly investigated issues beyond the specified limited scrutiny parameters, disallowed capital loss, and determined business loss without obtaining prior approval. Furthermore, the AO violated Section 144C by failing to issue a draft assessment order to the non-resident assessee before passing the final order. Consequently, the assessment order was deemed null and void due to jurisdictional defects and statutory non-compliance. The assessee's appeal was allowed, effectively invalidating the assessment proceedings.
ITAT Order: Procedural Violation in Limited Scrutiny Assessment The ITAT held that the Assessing Officer (AO) exceeded jurisdictional limits by expanding the scope of 'limited scrutiny' without following mandatory procedural requirements. The AO improperly investigated issues beyond the specified limited scrutiny parameters, disallowed capital loss, and determined business loss without obtaining prior approval. Furthermore, the AO violated Section 144C by failing to issue a draft assessment order to the non-resident assessee before passing the final order. Consequently, the assessment order was deemed null and void due to jurisdictional defects and statutory non-compliance. The assessee's appeal was allowed, effectively invalidating the assessment proceedings.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
