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...
The HC held that the impugned assessment was vitiated by breach of natural justice because the petitioner was not given an opportunity to show cause in respect of the impugned additions: the assessment did not record an unexplained bank credit under s.69A but instead treated payments for two immovable property purchases as unexplained, and an income addition under s.56(2)(x) was also not raised in the Show Cause Notice. Consequently, the HC set aside the assessment order, the demand notice and the penalty notices, and remanded the matter to the AO to issue a fresh show cause notice and thereafter proceed afresh to its logical conclusion.
The HC held that the impugned assessment was vitiated by breach of natural justice because the petitioner was not given an opportunity to show cause in respect of the impugned additions: the assessment did not record an unexplained bank credit under s.69A but instead treated payments for two immovable property purchases as unexplained, and an income addition under s.56(2)(x) was also not raised in the Show Cause Notice. Consequently, the HC set aside the assessment order, the demand notice and the penalty notices, and remanded the matter to the AO to issue a fresh show cause notice and thereafter proceed afresh to its logical conclusion.
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TaxTMI 
TaxTMI 
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