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...
Reassessment notices under Section 148 must be issued within the applicable limitation period. The original six-year period expired on 31 March 2020, while the relevant extension notification covered only notices whose original limitation expired on 31 March 2021; it therefore did not extend time for a notice issued on 1 April 2021. Such notice was time-barred, requiring the consequential assessment orders to be set aside. Section 292BB addresses defects in service where an assessee participates in proceedings despite ineffective service; it cannot validate a reassessment notice issued after the statutory limitation period.
Reassessment notices under Section 148 must be issued within the applicable limitation period. The original six-year period expired on 31 March 2020, while the relevant extension notification covered only notices whose original limitation expired on 31 March 2021; it therefore did not extend time for a notice issued on 1 April 2021. Such notice was time-barred, requiring the consequential assessment orders to be set aside. Section 292BB addresses defects in service where an assessee participates in proceedings despite ineffective service; it cannot validate a reassessment notice issued after the statutory limitation period.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
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