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 ITAT set aside the Ld. CIT(A)'s legal finding in favour of the assessee because the assessee failed to raise the objection mandated by s.124. The matter is remitted to the CIT(A) for fresh adjudication on the merits, directing that the appeal be decided after considering the assessee's submissions and material and after affording a reasonable opportunity of hearing; the assessee is directed to cooperate for expeditious disposal. Procedurally, the tribunal dismissed Revenue's grounds 2-7 and allowed ground 1. The tribunal's order requires the CIT(A) to re-evaluate jurisdictional and transfer-related issues in light of applicable statutory provisions during the rehearing.
The ITAT set aside the Ld. CIT(A)'s legal finding in favour of the assessee because the assessee failed to raise the objection mandated by s.124. The matter is remitted to the CIT(A) for fresh adjudication on the merits, directing that the appeal be decided after considering the assessee's submissions and material and after affording a reasonable opportunity of hearing; the assessee is directed to cooperate for expeditious disposal. Procedurally, the tribunal dismissed Revenue's grounds 2-7 and allowed ground 1. The tribunal's order requires the CIT(A) to re-evaluate jurisdictional and transfer-related issues in light of applicable statutory provisions during the rehearing.
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TaxTMI 
TaxTMI 
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