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...
Service of a valid reassessment notice is a jurisdictional condition precedent to reopening an assessment. The Assessing Officer bears the burden of proving actual service; absence of a valid postal receipt or other reliable proof leaves the jurisdictional requirement unsatisfied. Filing a return and participating in proceedings following an inquiry notice cannot cure non-service through consent, waiver or estoppel. Non-service is an incurable jurisdictional defect, rendering the reassessment proceedings and consequential assessment void ab initio.
Service of a valid reassessment notice is a jurisdictional condition precedent to reopening an assessment. The Assessing Officer bears the burden of proving actual service; absence of a valid postal receipt or other reliable proof leaves the jurisdictional requirement unsatisfied. Filing a return and participating in proceedings following an inquiry notice cannot cure non-service through consent, waiver or estoppel. Non-service is an incurable jurisdictional defect, rendering the reassessment proceedings and consequential assessment void ab initio.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
