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 the assessment order under Section 144 read with Section 147 was invalid due to non-service of notice on the petitioners, who are the legal heirs of the deceased assessee. The respondent failed to produce evidence of proper service of notice, as only dispatch receipts from the Postal Department were available, lacking acknowledgment of receipt. The Court emphasized the necessity for the Income Tax Department to maintain integrated and reliable records of notice service akin to the Court's system. Since no proof of notice service on the petitioners was furnished and they were not brought on record as legal heirs, the orders passed against them without proper notice were quashed. The writ petition was allowed accordingly.
The HC held that the assessment order under Section 144 read with Section 147 was invalid due to non-service of notice on the petitioners, who are the legal heirs of the deceased assessee. The respondent failed to produce evidence of proper service of notice, as only dispatch receipts from the Postal Department were available, lacking acknowledgment of receipt. The Court emphasized the necessity for the Income Tax Department to maintain integrated and reliable records of notice service akin to the Court's system. Since no proof of notice service on the petitioners was furnished and they were not brought on record as legal heirs, the orders passed against them without proper notice were quashed. The writ petition was allowed accordingly.
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