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...
Mandatory statutory notice prior to framing an assessment is required even where a return is filed in response to a notice under reassessment proceedings; if the Assessing Officer takes the filed return as the starting point for computation and acts upon it, pending electronic verification or later submission of a manual verification does not alone invalidate the return. An assessment completed without issuing the mandatory notice under the statutory provision governing notice before assessment is a jurisdictional defect and vitiates the assessment framed under reassessment provisions, resulting in the quashing of the assessment for the relevant year.
Mandatory statutory notice prior to framing an assessment is required even where a return is filed in response to a notice under reassessment proceedings; if the Assessing Officer takes the filed return as the starting point for computation and acts upon it, pending electronic verification or later submission of a manual verification does not alone invalidate the return. An assessment completed without issuing the mandatory notice under the statutory provision governing notice before assessment is a jurisdictional defect and vitiates the assessment framed under reassessment provisions, resulting in the quashing of the assessment for the relevant year.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
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