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...
Section 212(1)(c) requires a demonstrable and reasoned formation of opinion based on cogent, relevant circumstances before an investigation is assigned to SFIO. The statutory order itself must disclose the material considered and the basis for both the investigation and its assignment; later committee minutes, affidavits, or investigation material cannot cure a deficient order. A prior dismissal of a co-accused's petition as premature, with liberty to pursue remedies later, does not create res judicata or bar scrutiny of the initiating action. The SFIO investigation order and consequential proceedings, including the prosecution complaint, were quashed.
Section 212(1)(c) requires a demonstrable and reasoned formation of opinion based on cogent, relevant circumstances before an investigation is assigned to SFIO. The statutory order itself must disclose the material considered and the basis for both the investigation and its assignment; later committee minutes, affidavits, or investigation material cannot cure a deficient order. A prior dismissal of a co-accused's petition as premature, with liberty to pursue remedies later, does not create res judicata or bar scrutiny of the initiating action. The SFIO investigation order and consequential proceedings, including the prosecution complaint, were quashed.
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TaxTMI 
TaxTMI 
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