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...
The Petitioner (an anonymized corporate assessee) moved the HC challenging territorial jurisdiction and validity of reopening under s.148 of the IT Act read with the extended limitation provisions under TOLA; the Court held that, following relocation of the Petitioner's registered office to Mumbai and substantial events arising within the HC's territory, a substantial part of the cause of action arose within the HC's jurisdiction under Art.226(2), rejecting the forum conveniens objection. Applying binding precedent, the HC set aside the impugned s.148 notice and all consequential proceedings, thereby quashing the reopening and terminating the assessment action initiated pursuant to that notice.
The Petitioner (an anonymized corporate assessee) moved the HC challenging territorial jurisdiction and validity of reopening under s.148 of the IT Act read with the extended limitation provisions under TOLA; the Court held that, following relocation of the Petitioner's registered office to Mumbai and substantial events arising within the HC's territory, a substantial part of the cause of action arose within the HC's jurisdiction under Art.226(2), rejecting the forum conveniens objection. Applying binding precedent, the HC set aside the impugned s.148 notice and all consequential proceedings, thereby quashing the reopening and terminating the assessment action initiated pursuant to that notice.
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TaxTMI 
TaxTMI 
of 4918 
