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...
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Assessment orders become effective only when signed, and dating an order within time does not satisfy the statutory limit if signature follows later. The HC held that for AY 2023-24, the limitation under section 153 expired on 31 March 2025, but the assessment order was digitally signed only on 25 December 2025. As the computation sheet and notice of demand were also signed after expiry of limitation, they were not validly made within time. Treating signature as an essential requirement of legal validity, the Court held the assessment order, computation sheet and notice of demand to be time-barred and quashed them.
Assessment orders become effective only when signed, and dating an order within time does not satisfy the statutory limit if signature follows later. The HC held that for AY 2023-24, the limitation under section 153 expired on 31 March 2025, but the assessment order was digitally signed only on 25 December 2025. As the computation sheet and notice of demand were also signed after expiry of limitation, they were not validly made within time. Treating signature as an essential requirement of legal validity, the Court held the assessment order, computation sheet and notice of demand to be time-barred and quashed them.
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