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...
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HC quashed the reopening and consequential proceedings in favour of the assessee. The court found the notice issued under s.148A(b) for AY 2014-15 impermissibly relied on the return and assessment materials of a different year (AY 2013-14), so the Revenue lacked foundational information to form reasons to believe for reopening under s.147. Further, the jurisdictional officer initiated proceedings beyond the limitation prescribed by amended s.149 (effective 01.04.2021), and the show-cause notice dated 23.05.2022 did not disclose information pertinent to AY 2014-15. For these reasons the HC held the impugned notice and proceedings void and quashed them.
HC quashed the reopening and consequential proceedings in favour of the assessee. The court found the notice issued under s.148A(b) for AY 2014-15 impermissibly relied on the return and assessment materials of a different year (AY 2013-14), so the Revenue lacked foundational information to form reasons to believe for reopening under s.147. Further, the jurisdictional officer initiated proceedings beyond the limitation prescribed by amended s.149 (effective 01.04.2021), and the show-cause notice dated 23.05.2022 did not disclose information pertinent to AY 2014-15. For these reasons the HC held the impugned notice and proceedings void and quashed them.
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