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...
Reassessments reopened under the income tax reassessment provision on the basis of incriminating material discovered during searches under the search provisions are excluded from the Direct Tax Vivad Se Vishwas Scheme by operation of the statutory exclusion in Section 96; where reassessment stems from search-related material the petitioner is ineligible and the court will not read temporal cut-offs or carve-outs into the statute. Clarificatory circulars identifying search-based assessments do not displace or override the statutory exclusion and cannot bring such cases within the Scheme.
Reassessments reopened under the income tax reassessment provision on the basis of incriminating material discovered during searches under the search provisions are excluded from the Direct Tax Vivad Se Vishwas Scheme by operation of the statutory exclusion in Section 96; where reassessment stems from search-related material the petitioner is ineligible and the court will not read temporal cut-offs or carve-outs into the statute. Clarificatory circulars identifying search-based assessments do not displace or override the statutory exclusion and cannot bring such cases within the Scheme.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
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