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...
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The reassessment procedure under section 148 was held invalid where the assessee was not supplied the adverse material relied upon for the section 148A(b) notice and the order under section 148A(d) did not deal with the factual objections raised in reply. The Tribunal noted that the assessee had sought the material said to connect it with accommodation entries, yet only a general narration was furnished and the reply was not meaningfully considered. Because the statutory pre-notice process was not properly followed, the assumption of jurisdiction under section 148 was vitiated. The notice under section 148, the section 148A(d) order, and the reassessment were quashed.
The reassessment procedure under section 148 was held invalid where the assessee was not supplied the adverse material relied upon for the section 148A(b) notice and the order under section 148A(d) did not deal with the factual objections raised in reply. The Tribunal noted that the assessee had sought the material said to connect it with accommodation entries, yet only a general narration was furnished and the reply was not meaningfully considered. Because the statutory pre-notice process was not properly followed, the assumption of jurisdiction under section 148 was vitiated. The notice under section 148, the section 148A(d) order, and the reassessment were quashed.
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