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 quashed reassessment initiated u/s 147 as the AO lacked valid reasons to form belief that income of the assessee had escaped assessment. The tribunal found evidentiary support for sales to an unnamed counterparty, receipt of sale proceeds through banking channels, and no rebuttal by the AO to impugn genuineness; mere non-filing of returns by the counterparty did not suffice to treat receipts as unexplained cash credit u/s 68 or to constitute a reason to form belief under s.147. Reopening was also held to amount to impermissible change of opinion since identical sales were examined and accepted in the original s.143(3) assessment; reassessment was therefore invalid.
ITAT quashed reassessment initiated u/s 147 as the AO lacked valid reasons to form belief that income of the assessee had escaped assessment. The tribunal found evidentiary support for sales to an unnamed counterparty, receipt of sale proceeds through banking channels, and no rebuttal by the AO to impugn genuineness; mere non-filing of returns by the counterparty did not suffice to treat receipts as unexplained cash credit u/s 68 or to constitute a reason to form belief under s.147. Reopening was also held to amount to impermissible change of opinion since identical sales were examined and accepted in the original s.143(3) assessment; reassessment was therefore invalid.
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TaxTMI 
TaxTMI 
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