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 examines adequacy of service of statutory pre-reopening notice and the right to be heard; the court found doubt as to proper service of the notice under the statute and concluded that the taxpayer was likely deprived of a fair opportunity to present its case, consequently setting aside the subsequent notice and order issued on April 8, 2024. The operative effect requires the taxpayer to file a reply to the show-cause notice dated March 8, 2024 within two weeks, after which the assessing officer must reconsider whether reopening and issuance of a reassessment notice is justified.
Reopening of assessment examines adequacy of service of statutory pre-reopening notice and the right to be heard; the court found doubt as to proper service of the notice under the statute and concluded that the taxpayer was likely deprived of a fair opportunity to present its case, consequently setting aside the subsequent notice and order issued on April 8, 2024. The operative effect requires the taxpayer to file a reply to the show-cause notice dated March 8, 2024 within two weeks, after which the assessing officer must reconsider whether reopening and issuance of a reassessment notice is justified.
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TaxTMI 
TaxTMI 
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