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...
Notice under section 143(2) is a mandatory jurisdictional condition for completing a section 153C assessment that departs from a return filed in response to the statutory notice. Complete non-issuance is not a procedural irregularity capable of cure through section 292BB. Applying the view favourable to assessees amid divergent non-jurisdictional decisions, assessments completed under section 153C read with section 143(3) without such notice were quashed. Challenges to additions and other merits remained unadjudicated.
Notice under section 143(2) is a mandatory jurisdictional condition for completing a section 153C assessment that departs from a return filed in response to the statutory notice. Complete non-issuance is not a procedural irregularity capable of cure through section 292BB. Applying the view favourable to assessees amid divergent non-jurisdictional decisions, assessments completed under section 153C read with section 143(3) without such notice were quashed. Challenges to additions and other merits remained unadjudicated.
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TaxTMI 
TaxTMI 
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