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...
ITAT held that spot verification conducted by the ACIT TDS for the relevant years was without authority of law and therefore void ab initio, because the proviso to section 133A required prior approval of the Joint Commissioner or Joint Director which was not obtained for FY 2012-13 and 2013-14. Consequently, any consequential action or orders passed under sections 201/201(1A) based on that verification could not be sustained. The tribunal quashed the impugned proceedings and directed that no cognizance be taken of the illegal survey material; the appeal of the assessee was allowed and the orders founded on the defective spot verification were set aside.
ITAT held that spot verification conducted by the ACIT TDS for the relevant years was without authority of law and therefore void ab initio, because the proviso to section 133A required prior approval of the Joint Commissioner or Joint Director which was not obtained for FY 2012-13 and 2013-14. Consequently, any consequential action or orders passed under sections 201/201(1A) based on that verification could not be sustained. The tribunal quashed the impugned proceedings and directed that no cognizance be taken of the illegal survey material; the appeal of the assessee was allowed and the orders founded on the defective spot verification were set aside.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
