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...
Tribunal power to admit belated additional grounds was upheld where those grounds go to the root of the dispute and all relevant facts are already on record; accordingly the tribunal admitted the assessee's additional ground. Reopening of assessment was held invalid because the reassessment was initiated solely on specified cash deposits yet the assessing officer made an unrelated addition by disallowing an exemption that was not part of the recorded reasons for reopening; since the addition did not flow from the recorded reasons, the reopening was quashed and the appeal allowed.
Tribunal power to admit belated additional grounds was upheld where those grounds go to the root of the dispute and all relevant facts are already on record; accordingly the tribunal admitted the assessee's additional ground. Reopening of assessment was held invalid because the reassessment was initiated solely on specified cash deposits yet the assessing officer made an unrelated addition by disallowing an exemption that was not part of the recorded reasons for reopening; since the addition did not flow from the recorded reasons, the reopening was quashed and the appeal allowed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
