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 allowed the appeal and quashed the order passed under sections 201(1)/201(1A) as void ab initio for want of jurisdiction. The Tribunal held that the Assessing Officer (TDS) of a different jurisdiction had assumed jurisdiction and issued a default TDS notice for alleged non-deduction on external development charge payments to a local urban development authority, whereas the assessee fell within the territorial jurisdiction of another Assessing Officer. In light of the uncontroverted jurisdictional defect, the impugned order could not be sustained; the grounds raised by the assessee were allowed and the order was set aside.
ITAT allowed the appeal and quashed the order passed under sections 201(1)/201(1A) as void ab initio for want of jurisdiction. The Tribunal held that the Assessing Officer (TDS) of a different jurisdiction had assumed jurisdiction and issued a default TDS notice for alleged non-deduction on external development charge payments to a local urban development authority, whereas the assessee fell within the territorial jurisdiction of another Assessing Officer. In light of the uncontroverted jurisdictional defect, the impugned order could not be sustained; the grounds raised by the assessee were allowed and the order was set aside.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
