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...
Invocation of the tax search-transfer provision cannot rest on material obtained from public-domain sources or other external records that were not part of the seized documents; reliance on such material defeats the required nexus to seized incriminating material and renders jurisdictional exercise invalid. Where incriminating material "relating to" a third person is transmitted, it is mandatory that the Assessing Officer of the searched person record and communicate a satisfaction note before the jurisdictional Assessing Officer may proceed; proceedings initiated without that satisfaction note are without jurisdiction and unsustainable. Notices founded on external/public material or lacking the mandatory satisfaction note were quashed.
Invocation of the tax search-transfer provision cannot rest on material obtained from public-domain sources or other external records that were not part of the seized documents; reliance on such material defeats the required nexus to seized incriminating material and renders jurisdictional exercise invalid. Where incriminating material "relating to" a third person is transmitted, it is mandatory that the Assessing Officer of the searched person record and communicate a satisfaction note before the jurisdictional Assessing Officer may proceed; proceedings initiated without that satisfaction note are without jurisdiction and unsustainable. Notices founded on external/public material or lacking the mandatory satisfaction note were quashed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
