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 issued in the name of an amalgamating company that had ceased to exist, after the Revenue had been informed of the amalgamation, constitutes a jurisdictional defect rather than a procedural irregularity. Section 292B does not cure this defect, and participation in assessment proceedings does not create an estoppel against law. The assessment was quashed as void ab initio on the additional jurisdictional ground, while the remaining merits grounds were left open as academic.
Assessment issued in the name of an amalgamating company that had ceased to exist, after the Revenue had been informed of the amalgamation, constitutes a jurisdictional defect rather than a procedural irregularity. Section 292B does not cure this defect, and participation in assessment proceedings does not create an estoppel against law. The assessment was quashed as void ab initio on the additional jurisdictional ground, while the remaining merits grounds were left open as academic.
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TaxTMI 
TaxTMI 
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