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...
An assessment or transfer pricing order passed in the name of a dissolved amalgamating company is void ab initio when the successor entity had already informed the tax authorities of the amalgamation and furnished the NCLT-approved scheme. Applying Maruti Suzuki India Ltd., the ITAT held that such an error is not a curable procedural defect under section 292B. The transfer pricing order, draft assessment order and final assessment order, all issued after dissolution in the name and PAN of the non-existent company, were therefore bad in law.
An assessment or transfer pricing order passed in the name of a dissolved amalgamating company is void ab initio when the successor entity had already informed the tax authorities of the amalgamation and furnished the NCLT-approved scheme. Applying Maruti Suzuki India Ltd., the ITAT held that such an error is not a curable procedural defect under section 292B. The transfer pricing order, draft assessment order and final assessment order, all issued after dissolution in the name and PAN of the non-existent company, were therefore bad in law.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
