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 held that notices issued u/s 143(2) dated 17/08/2018 and 23/08/2018 were invalid for failing to specify whether scrutiny was "limited" (CASS), "complete" (CASS) or "complete manual" as mandated by the Board format notified 23.06.2017; the CBDT instruction under s.119 is mandatory and binds income-tax authorities. The Tribunal affirmed that the revenue bears the burden to demonstrate strict compliance with the prescribed CASS/notice format and approval procedures. Consequently the assessment order framed u/s 143(3) dated 24/12/2019 was quashed for lack of jurisdiction due to non-compliance with mandatory CBDT instructions.
ITAT held that notices issued u/s 143(2) dated 17/08/2018 and 23/08/2018 were invalid for failing to specify whether scrutiny was "limited" (CASS), "complete" (CASS) or "complete manual" as mandated by the Board format notified 23.06.2017; the CBDT instruction under s.119 is mandatory and binds income-tax authorities. The Tribunal affirmed that the revenue bears the burden to demonstrate strict compliance with the prescribed CASS/notice format and approval procedures. Consequently the assessment order framed u/s 143(3) dated 24/12/2019 was quashed for lack of jurisdiction due to non-compliance with mandatory CBDT instructions.
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