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...
HC quashed and set aside the impugned order passed u/s 148A(d) and the consequential notice u/s 148, holding that initiation of reassessment proceedings was vitiated by breach of natural justice because the adverse Verification Report relied upon was not furnished to the petitioner prior to issuance of the notice u/s 148A(b). The court remanded the matter to the respondent authority to proceed afresh from the stage of issuance of notice u/s 148A(b), directing the respondent to supply the Verification Report to the petitioner within a reasonable time and permitting the petitioner to file a fresh reply. The prior actions of the department are set aside as invalid for non-supply of material relied upon.
HC quashed and set aside the impugned order passed u/s 148A(d) and the consequential notice u/s 148, holding that initiation of reassessment proceedings was vitiated by breach of natural justice because the adverse Verification Report relied upon was not furnished to the petitioner prior to issuance of the notice u/s 148A(b). The court remanded the matter to the respondent authority to proceed afresh from the stage of issuance of notice u/s 148A(b), directing the respondent to supply the Verification Report to the petitioner within a reasonable time and permitting the petitioner to file a fresh reply. The prior actions of the department are set aside as invalid for non-supply of material relied upon.
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TaxTMI 
TaxTMI 
of 4918 
