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...
HC quashed and set aside the reopening order and notice. The court held that the AO erred in assuming jurisdiction under s.147 because credits in the account of a cooperative bank during the demonetisation window related to AY 2017-18, not AY 2018-19, and thus could not form the basis for reopening for the impugned year. The AO's reliance solely on transactions with an unnamed trader and the petitioner's alleged failure to produce books was inadequate to establish a prima facie escapement of income. The petitioner had already furnished ledger extracts and the tax audit report in response to the s.148A(b) notice. Consequently, the order under s.148A(d) and the s.148 notice were invalid and set aside.
HC quashed and set aside the reopening order and notice. The court held that the AO erred in assuming jurisdiction under s.147 because credits in the account of a cooperative bank during the demonetisation window related to AY 2017-18, not AY 2018-19, and thus could not form the basis for reopening for the impugned year. The AO's reliance solely on transactions with an unnamed trader and the petitioner's alleged failure to produce books was inadequate to establish a prima facie escapement of income. The petitioner had already furnished ledger extracts and the tax audit report in response to the s.148A(b) notice. Consequently, the order under s.148A(d) and the s.148 notice were invalid and set aside.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
