Assessing Officer jurisdiction after statutory transfer invalidates reassessment notices issued by transferor officers and nullifies resulting proceed...
Consequential appeal-effect orders must implement rectification deleting working-capital adjustments and reconsider the resulting arm's-length range c...
Discounted cash flow valuation protects share premium where projections are reasonable, while audited book expenses defeat unexplained-expenditure add...
Section 54 construction relief survives pre-transfer commencement when completion occurs within the statutory period, excluding ineligible spouse-owne...
Fraud classification show-cause notices founded on inconclusive forensic audit material cannot sustain action, permitting fresh proceedings on conclus...
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Third-party search material triggering reopening is governed, under the pre-amendment framework, by the search-assessment mechanism rather than ordinary reassessment. Material handover to the receiving Assessing Officer is treated as the third-party search date for computing the ten-year assessment block; consequently, the notice for AY 2013-14 was time-barred. Extended reassessment limitation also cannot be invoked by aggregating alleged expenditure from separate furniture and interior-work orders unless it relates to the same event or occasion. Distinct orders, payment dates and time periods constituted separate events, making the extended period unavailable. Reassessment notices for AYs 2013-14 and 2014-15 were therefore quashed as barred by limitation.
Third-party search material triggering reopening is governed, under the pre-amendment framework, by the search-assessment mechanism rather than ordinary reassessment. Material handover to the receiving Assessing Officer is treated as the third-party search date for computing the ten-year assessment block; consequently, the notice for AY 2013-14 was time-barred. Extended reassessment limitation also cannot be invoked by aggregating alleged expenditure from separate furniture and interior-work orders unless it relates to the same event or occasion. Distinct orders, payment dates and time periods constituted separate events, making the extended period unavailable. Reassessment notices for AYs 2013-14 and 2014-15 were therefore quashed as barred by limitation.
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