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 ITAT set aside the assessment framed u/s.143(3) as void for want of jurisdiction, holding that no valid transfer order u/s.127 had been passed to transfer the proceeding from the original AO to the assessing AO and that the assessing AO had not issued notice u/s.143(2). The Tribunal allowed the assessee's appeal, finding the assessment quashed ab initio for lack of the mandatory s.127 transfer prerequisite and consequent absence of proper notice, and relied on controlling appellate precedent permitting challenge to jurisdictional defects that go to the root of the matter. The impugned assessment is therefore quashed and the appeal is allowed.
The ITAT set aside the assessment framed u/s.143(3) as void for want of jurisdiction, holding that no valid transfer order u/s.127 had been passed to transfer the proceeding from the original AO to the assessing AO and that the assessing AO had not issued notice u/s.143(2). The Tribunal allowed the assessee's appeal, finding the assessment quashed ab initio for lack of the mandatory s.127 transfer prerequisite and consequent absence of proper notice, and relied on controlling appellate precedent permitting challenge to jurisdictional defects that go to the root of the matter. The impugned assessment is therefore quashed and the appeal is allowed.
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