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...
The HC held that both DRP directions and assessment orders were invalid due to absence of Document Identification Numbers (DIN). The court determined that DRP proceedings, conducted by a collegium of three Income Tax Commissioners, fell within the scope of the circular requiring DIN generation. The appellant failed to provide explanation for non-generation of DIN in the assessment order. Consequently, the HC found no merit in the appeal and answered the substantial questions of law unfavorably to the appellant, invalidating both the DRP directions and assessment order for non-compliance with DIN requirements under the applicable circular provisions.
The HC held that both DRP directions and assessment orders were invalid due to absence of Document Identification Numbers (DIN). The court determined that DRP proceedings, conducted by a collegium of three Income Tax Commissioners, fell within the scope of the circular requiring DIN generation. The appellant failed to provide explanation for non-generation of DIN in the assessment order. Consequently, the HC found no merit in the appeal and answered the substantial questions of law unfavorably to the appellant, invalidating both the DRP directions and assessment order for non-compliance with DIN requirements under the applicable circular provisions.
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TaxTMI 
TaxTMI 
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