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...
Reassessment notices issued under the new regime were held time-barred because, for notices originally issued between 01/04/2021 and 30/06/2021, only the surviving time available up to 30/06/2021 could be used after excluding the stayed period and the two weeks allowed for response. Applying the Supreme Court rulings in Rajeev Bansal and Ashish Agarwal, the Tribunal held that the fresh notice had to be issued within the remaining limitation under section 149. In this case, the notice issued on 25/07/2022 exceeded that limit, so the reassessment proceedings and assessment orders were quashed, with other grounds left open.
Reassessment notices issued under the new regime were held time-barred because, for notices originally issued between 01/04/2021 and 30/06/2021, only the surviving time available up to 30/06/2021 could be used after excluding the stayed period and the two weeks allowed for response. Applying the Supreme Court rulings in Rajeev Bansal and Ashish Agarwal, the Tribunal held that the fresh notice had to be issued within the remaining limitation under section 149. In this case, the notice issued on 25/07/2022 exceeded that limit, so the reassessment proceedings and assessment orders were quashed, with other grounds left open.
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