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 quashed the impugned reopening assessments for AY 2016-17 and 2017-18, holding that respondent(s) failed to disclose reasons for reopening and issued final assessment orders without providing a draft assessment order, thereby violating principles of natural justice and established judicial precedent. For AY 2018-19, the HC quashed the order passed under s.148A(d) and the notice under s.148, finding denial of opportunity to seek adjournment and breach of s.148A(c). The matter is remitted to the AO to afford the petitioner an opportunity to file a reply to the s.148A(b) notice and thereafter pass a fresh s.148A(d) order in accordance with law, preferably within 12 weeks.
The HC quashed the impugned reopening assessments for AY 2016-17 and 2017-18, holding that respondent(s) failed to disclose reasons for reopening and issued final assessment orders without providing a draft assessment order, thereby violating principles of natural justice and established judicial precedent. For AY 2018-19, the HC quashed the order passed under s.148A(d) and the notice under s.148, finding denial of opportunity to seek adjournment and breach of s.148A(c). The matter is remitted to the AO to afford the petitioner an opportunity to file a reply to the s.148A(b) notice and thereafter pass a fresh s.148A(d) order in accordance with law, preferably within 12 weeks.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
