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...
HC examined the challenge to an assessment order passed u/s 143(3) r/w s.144B on two grounds. On the first, alleging breach of natural justice, HC held against Assessee A, noting repeated show-cause notices, failure to furnish PAN, addresses, and details to establish creditworthiness, and thus no denial of fair opportunity. On the second, alleging non-compliance with mandatory faceless assessment under s.144B (effective from 01.04.2021), HC found Revenue had offered no justification for not following the faceless procedure and was silent in its counter. Holding the faceless regime mandatory, HC applied settled law, declared the assessment proceedings and order unsustainable, and quashed/set aside the impugned assessment, thereby allowing the petition on this ground in favour of Assessee A and against Revenue.
HC examined the challenge to an assessment order passed u/s 143(3) r/w s.144B on two grounds. On the first, alleging breach of natural justice, HC held against Assessee A, noting repeated show-cause notices, failure to furnish PAN, addresses, and details to establish creditworthiness, and thus no denial of fair opportunity. On the second, alleging non-compliance with mandatory faceless assessment under s.144B (effective from 01.04.2021), HC found Revenue had offered no justification for not following the faceless procedure and was silent in its counter. Holding the faceless regime mandatory, HC applied settled law, declared the assessment proceedings and order unsustainable, and quashed/set aside the impugned assessment, thereby allowing the petition on this ground in favour of Assessee A and against Revenue.
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TaxTMI 
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