Transfer pricing comparability prioritises reliable external CUPs and foreign-currency LIBOR benchmarks for exports, borrowings and delayed receivable...
Section 153C satisfaction and seized electronic records sustained unexplained-investment addition, subject to proportionate ownership-share verificati...
Natural justice in insolvency-professional discipline requires disclosed material; notices based on extraneous material and ignored defences are vitia...
Reopening beyond three years under section 149(1)(b) requires the escaped income to be represented in the form prescribed by law; mere reference to unrecorded scrap-sale receipts and an estimated profit basis was insufficient, so the reassessment for AYs 2019-20 and 2020-21 was quashed. Ambiguous section 148 notices that inconsistently stated the search basis showed non-application of mind, rendering the notices and reassessments for AYs 2021-22 and 2022-23 invalid. For searches conducted after 1 April 2021, the special post-2021 mechanism under sections 147/148, with prior approval under section 148B, prevails over regular assessment under section 143(3); accordingly, the section 143(3) assessments for AYs 2023-24 and 2024-25 were also quashed.
Reopening beyond three years under section 149(1)(b) requires the escaped income to be represented in the form prescribed by law; mere reference to unrecorded scrap-sale receipts and an estimated profit basis was insufficient, so the reassessment for AYs 2019-20 and 2020-21 was quashed. Ambiguous section 148 notices that inconsistently stated the search basis showed non-application of mind, rendering the notices and reassessments for AYs 2021-22 and 2022-23 invalid. For searches conducted after 1 April 2021, the special post-2021 mechanism under sections 147/148, with prior approval under section 148B, prevails over regular assessment under section 143(3); accordingly, the section 143(3) assessments for AYs 2023-24 and 2024-25 were also quashed.
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