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 of assessment challenged on the ground that an interest-free loan to a director constituted a deemed dividend; the Assessing Officer relied on alleged non-disclosure to invoke extended limitation. The court found audited accounts and the directors ledger disclosed the primary fact of the interest-free loan, so invocation of extended limitation and issuance of reassessment notice were jurisdictionally invalid; reassessment second time on the same transaction was arbitrary and contrary to the requirement that an assessee need only disclose primary facts, and violated equality, economic liberty and property protections, resulting in allowance of the writ petitions.
Reopening of assessment challenged on the ground that an interest-free loan to a director constituted a deemed dividend; the Assessing Officer relied on alleged non-disclosure to invoke extended limitation. The court found audited accounts and the directors ledger disclosed the primary fact of the interest-free loan, so invocation of extended limitation and issuance of reassessment notice were jurisdictionally invalid; reassessment second time on the same transaction was arbitrary and contrary to the requirement that an assessee need only disclose primary facts, and violated equality, economic liberty and property protections, resulting in allowance of the writ petitions.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
