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...
Reopening under s.147 based on alleged cash purchases reflected in TAS was challenged as an impermissible change of opinion after the AO had earlier dropped inquiry for want of evidence. The court held that "opinion" requires formation on available material; mere availability of transaction entries without corroborative data linking the assessee to the alleged counterparty did not amount to an opinion, particularly when the assessee denied any relationship, making verification impossible. Since the impugned s.148 notice relied on new, tangible material establishing the linkage, no jurisdictional error was shown and the reopening was upheld. - HC
Reopening under s.147 based on alleged cash purchases reflected in TAS was challenged as an impermissible change of opinion after the AO had earlier dropped inquiry for want of evidence. The court held that "opinion" requires formation on available material; mere availability of transaction entries without corroborative data linking the assessee to the alleged counterparty did not amount to an opinion, particularly when the assessee denied any relationship, making verification impossible. Since the impugned s.148 notice relied on new, tangible material establishing the linkage, no jurisdictional error was shown and the reopening was upheld. - HC
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