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...
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The ITAT held that the reopening of assessment under Section 148 issued after the assessee's death was invalid. The notice dated 31.03.2016 was served on the deceased, who passed away on 02.10.2015, rendering service impossible and the proceedings void ab initio. Under Section 159(2)(b), proceedings can be initiated against legal heirs if the assessee is deceased; however, the AO failed to issue the notice to the legal heirs before the limitation expired on 31.03.2016. Consequently, the reopening did not comply with the mandatory conditions under Section 148, and the assessment proceedings were quashed for non-compliance with statutory requirements and breach of natural justice. The appeal was allowed, affirming that a notice issued to a deceased person is invalid and cannot sustain reassessment proceedings.
The ITAT held that the reopening of assessment under Section 148 issued after the assessee's death was invalid. The notice dated 31.03.2016 was served on the deceased, who passed away on 02.10.2015, rendering service impossible and the proceedings void ab initio. Under Section 159(2)(b), proceedings can be initiated against legal heirs if the assessee is deceased; however, the AO failed to issue the notice to the legal heirs before the limitation expired on 31.03.2016. Consequently, the reopening did not comply with the mandatory conditions under Section 148, and the assessment proceedings were quashed for non-compliance with statutory requirements and breach of natural justice. The appeal was allowed, affirming that a notice issued to a deceased person is invalid and cannot sustain reassessment proceedings.
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