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 ITAT quashed the assessment framed by the AO under section 143(3) as being void ab initio because it was predicated on a notice issued under section 143(2) that did not conform to the CBDT-prescribed format. Relying on relevant precedents, the Tribunal held the defective 143(2) notice-specifying only "computer aided scrutiny selection" without indicating limited or complete scrutiny or mandatory manual review-vitiated the consequent assessment proceedings. The appellate order allows the assessee's additional ground, sets aside the assessment dated 30.12.2019, and directs that any future proceedings comply strictly with statutory and CBDT procedural requirements.
The ITAT quashed the assessment framed by the AO under section 143(3) as being void ab initio because it was predicated on a notice issued under section 143(2) that did not conform to the CBDT-prescribed format. Relying on relevant precedents, the Tribunal held the defective 143(2) notice-specifying only "computer aided scrutiny selection" without indicating limited or complete scrutiny or mandatory manual review-vitiated the consequent assessment proceedings. The appellate order allows the assessee's additional ground, sets aside the assessment dated 30.12.2019, and directs that any future proceedings comply strictly with statutory and CBDT procedural requirements.
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TaxTMI 
TaxTMI 
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