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 taxpayer's appeal, holding that the sanction issued under section 151(i) for issuance of notice under section 148 and consequential order under section 148A(d) (post three years) was infirm; the correct sanction ought to have been under section 151(ii). Consequently, the reassessment proceedings under section 147 were vitiated. The Principal Commissioner of Income-tax, in exercise of revisionary jurisdiction under section 263, lacked competence to set aside a non-est reassessment order and to direct the Assessing Officer to pass a fresh assessment. The revision order was quashed and the reassessment proceedings held invalid.
ITAT allowed the taxpayer's appeal, holding that the sanction issued under section 151(i) for issuance of notice under section 148 and consequential order under section 148A(d) (post three years) was infirm; the correct sanction ought to have been under section 151(ii). Consequently, the reassessment proceedings under section 147 were vitiated. The Principal Commissioner of Income-tax, in exercise of revisionary jurisdiction under section 263, lacked competence to set aside a non-est reassessment order and to direct the Assessing Officer to pass a fresh assessment. The revision order was quashed and the reassessment proceedings held invalid.
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