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...
Assessment under section 147 read with section 144B was not vitiated merely because notice under section 143(2) was issued by the Jurisdictional Assessing Officer and the reassessment was completed through the faceless regime; the Tribunal held that concurrent jurisdiction survives and rejected the legal challenge. On merits, however, additions based on treating full sale consideration as short-term capital gain, ad hoc estimation of contract and professional receipts, and addition of rent receipts as business income were set aside because they were made without proper verification of cost, books, reconciliation, or supporting documents. The matter was remanded for fresh examination, with the assessee's non-compliance noted as a material factor.
Assessment under section 147 read with section 144B was not vitiated merely because notice under section 143(2) was issued by the Jurisdictional Assessing Officer and the reassessment was completed through the faceless regime; the Tribunal held that concurrent jurisdiction survives and rejected the legal challenge. On merits, however, additions based on treating full sale consideration as short-term capital gain, ad hoc estimation of contract and professional receipts, and addition of rent receipts as business income were set aside because they were made without proper verification of cost, books, reconciliation, or supporting documents. The matter was remanded for fresh examination, with the assessee's non-compliance noted as a material factor.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
