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...
Reassessment proceedings were held invalid because, prior to issuance of the order under section 148A(d) and notice under section 148 dated 31.03.2022 by the jurisdictional AO, the Central Government had notified the faceless scheme under section 151A mandating that actions under sections 148A(b), 148A(d) and issuance of notice under section 148 be undertaken only through the faceless mechanism. Since the notice was issued contrary to this statutory mandate, the non-compliance was treated as violative of the rule of law, rendering the notice unsustainable; consequently, the reassessment order passed under section 147 read with section 144 was quashed and the appeal was allowed. - ITAT
Reassessment proceedings were held invalid because, prior to issuance of the order under section 148A(d) and notice under section 148 dated 31.03.2022 by the jurisdictional AO, the Central Government had notified the faceless scheme under section 151A mandating that actions under sections 148A(b), 148A(d) and issuance of notice under section 148 be undertaken only through the faceless mechanism. Since the notice was issued contrary to this statutory mandate, the non-compliance was treated as violative of the rule of law, rendering the notice unsustainable; consequently, the reassessment order passed under section 147 read with section 144 was quashed and the appeal was allowed. - ITAT
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