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 under s. 143(3) as the statutory scrutiny notice under s. 143(2) was issued by a non-jurisdictional ITO instead of the DCIT who alone had jurisdiction given the assessee's return exceeded ₹20 lakh. The Tribunal held the assessment initiation was vitiated by jurisdictional defect, not curable, because the required jurisdictional officer did not issue the s. 143(2) notice nor complete the assessment. Having regard to settled coordinate bench rulings, the assessment was declared invalid and set aside, and the assessee's additional grounds challenging validity were allowed.
The ITAT quashed the assessment framed under s. 143(3) as the statutory scrutiny notice under s. 143(2) was issued by a non-jurisdictional ITO instead of the DCIT who alone had jurisdiction given the assessee's return exceeded ₹20 lakh. The Tribunal held the assessment initiation was vitiated by jurisdictional defect, not curable, because the required jurisdictional officer did not issue the s. 143(2) notice nor complete the assessment. Having regard to settled coordinate bench rulings, the assessment was declared invalid and set aside, and the assessee's additional grounds challenging validity were allowed.
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TaxTMI 
TaxTMI 
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