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...
Search-assessment jurisdiction is confined to the statutory ten-year block computed from the search assessment year; assessments outside that period lack jurisdiction. Extension beyond six years requires escaped income represented by an asset: foreign travel expenditure and unsecured loans, being expenditure and liabilities respectively, do not meet that condition. In unabated years, additions must rest on incriminating material found during the search; disclosed transactions, recorded claims, prior-search statements, and material not proving the assessee's payment cannot sustain additions. Search assessments must also be completed within twelve months from the end of the financial year in which the last search authorisation was executed; completion thereafter is time-barred.
Search-assessment jurisdiction is confined to the statutory ten-year block computed from the search assessment year; assessments outside that period lack jurisdiction. Extension beyond six years requires escaped income represented by an asset: foreign travel expenditure and unsecured loans, being expenditure and liabilities respectively, do not meet that condition. In unabated years, additions must rest on incriminating material found during the search; disclosed transactions, recorded claims, prior-search statements, and material not proving the assessee's payment cannot sustain additions. Search assessments must also be completed within twelve months from the end of the financial year in which the last search authorisation was executed; completion thereafter is time-barred.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
