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...
The HC allowed the writ petition challenging reassessment proceedings, finding the notices under Sections 148A and 148 invalid due to non-compliance with faceless assessment provisions introduced by the Finance Act, 2021. The court quashed the impugned notices, following its previous ruling in a similar case. However, the order is subject to the outcome of the pending Supreme Court special leave petition challenging the earlier High Court decision. The jurisdictional Assessing Officer's proceedings were set aside, granting relief to the assessee on procedural grounds.
The HC allowed the writ petition challenging reassessment proceedings, finding the notices under Sections 148A and 148 invalid due to non-compliance with faceless assessment provisions introduced by the Finance Act, 2021. The court quashed the impugned notices, following its previous ruling in a similar case. However, the order is subject to the outcome of the pending Supreme Court special leave petition challenging the earlier High Court decision. The jurisdictional Assessing Officer's proceedings were set aside, granting relief to the assessee on procedural grounds.
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