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 the reopening of assessment under s.147/s.148 invalid, finding the AO's action amounted to impermissible change of opinion as no fresh material surfaced post-assessment and the original return and notes were fully considered; the sanction by the CIT(A) was mechanical ("yes, I am satisfied") and therefore vitiated, so the reassessment proceedings and notice under s.148 are quashed. Separately, the Tribunal upheld the assessee's accounting treatment of goodwill under the purchase method for computation of book profit under s.115JB, directing the AO to delete adjustments and allow amortisation/depreciation on goodwill as reflected in the approved merger scheme and audited financials.
ITAT held the reopening of assessment under s.147/s.148 invalid, finding the AO's action amounted to impermissible change of opinion as no fresh material surfaced post-assessment and the original return and notes were fully considered; the sanction by the CIT(A) was mechanical ("yes, I am satisfied") and therefore vitiated, so the reassessment proceedings and notice under s.148 are quashed. Separately, the Tribunal upheld the assessee's accounting treatment of goodwill under the purchase method for computation of book profit under s.115JB, directing the AO to delete adjustments and allow amortisation/depreciation on goodwill as reflected in the approved merger scheme and audited financials.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
