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...
Reopening of assessment beyond four years was held invalid because the assessee had disclosed complete books, audited financials, and ledgers for machinery rent, purchases, and carriage expenses during the original scrutiny, and the AO had examined cash payments and made an ad hoc disallowance after applying mind. The alleged Section 68 discrepancy in an unsecured loan ledger was found to be a transparent accounting misposting of a bank transfer by a partner, with no impact on cash balance or total liabilities, later rectified. In the absence of any fresh tangible material, the reopening amounted to a mere change of opinion barred by law; notice under Section 148 was quashed and the appeal was allowed - ITAT
Reopening of assessment beyond four years was held invalid because the assessee had disclosed complete books, audited financials, and ledgers for machinery rent, purchases, and carriage expenses during the original scrutiny, and the AO had examined cash payments and made an ad hoc disallowance after applying mind. The alleged Section 68 discrepancy in an unsecured loan ledger was found to be a transparent accounting misposting of a bank transfer by a partner, with no impact on cash balance or total liabilities, later rectified. In the absence of any fresh tangible material, the reopening amounted to a mere change of opinion barred by law; notice under Section 148 was quashed and the appeal was allowed - ITAT
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TaxTMI 
TaxTMI 
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