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...
Fresh assessment after Tribunal remand must be completed within the statutory period under Section 153, and failure to do so bars any further demand. The High Court held that where no assessment order was passed within the extended limitation period, the Assessing Officer could not keep the matter pending or rely on earlier findings independently of a consequential order. The consequence of non-compliance was that the return of income had to be accepted as filed. The writ petition was therefore allowed, and the assessee's return for AY 2014-15 was directed to be accepted.
Fresh assessment after Tribunal remand must be completed within the statutory period under Section 153, and failure to do so bars any further demand. The High Court held that where no assessment order was passed within the extended limitation period, the Assessing Officer could not keep the matter pending or rely on earlier findings independently of a consequential order. The consequence of non-compliance was that the return of income had to be accepted as filed. The writ petition was therefore allowed, and the assessee's return for AY 2014-15 was directed to be accepted.
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