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 held that the Assessing Officer could not reopen the assessment merely on a change of opinion. The court found that the petitioner had already disclosed all relevant facts during the original assessment, including TDS details and deductions under section 80IC. The reopening of assessment was deemed improper as it did not reveal any new information constituting income escapement. The court emphasized that reassessment is not equivalent to reviewing the original assessment order. The procedural provisions and amendments to sections 147 and 148 did not alter the fundamental principle against reopening assessments based solely on a different interpretation of existing information. Judgment was decided in favor of the assessee.
HC held that the Assessing Officer could not reopen the assessment merely on a change of opinion. The court found that the petitioner had already disclosed all relevant facts during the original assessment, including TDS details and deductions under section 80IC. The reopening of assessment was deemed improper as it did not reveal any new information constituting income escapement. The court emphasized that reassessment is not equivalent to reviewing the original assessment order. The procedural provisions and amendments to sections 147 and 148 did not alter the fundamental principle against reopening assessments based solely on a different interpretation of existing information. Judgment was decided in favor of the assessee.
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