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...
Where scrutiny assessment is completed through the e-proceedings mechanism, the prescribed procedure requires the Assessing Officer to sign the assessment order digitally. Because the assessment order in this case was admittedly passed through e-proceedings but was only manually signed, it did not conform to the binding procedure and the defect vitiated the assessment. The additional legal ground was therefore admitted, the assessment was quashed, and the remaining grounds were treated as academic.
Where scrutiny assessment is completed through the e-proceedings mechanism, the prescribed procedure requires the Assessing Officer to sign the assessment order digitally. Because the assessment order in this case was admittedly passed through e-proceedings but was only manually signed, it did not conform to the binding procedure and the defect vitiated the assessment. The additional legal ground was therefore admitted, the assessment was quashed, and the remaining grounds were treated as academic.
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