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...
Assessment was challenged for being confirmed without a reply to the show cause notice, raising breach of natural justice. The Court noted that the impugned order was passed only because no reply had been filed, while the record also showed attachment of the bank account and full recovery of the arrears for the relevant year. The matter was remitted for fresh consideration on merits, with liberty to the petitioner to file a reply with supporting documents and with prior notice before the fresh order. The remand was made conditional: if the reply was not filed within the stipulated time, the impugned assessment order would stand confirmed.
Assessment was challenged for being confirmed without a reply to the show cause notice, raising breach of natural justice. The Court noted that the impugned order was passed only because no reply had been filed, while the record also showed attachment of the bank account and full recovery of the arrears for the relevant year. The matter was remitted for fresh consideration on merits, with liberty to the petitioner to file a reply with supporting documents and with prior notice before the fresh order. The remand was made conditional: if the reply was not filed within the stipulated time, the impugned assessment order would stand confirmed.
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