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...
Revision under section 263 cannot rest solely on an Assessing Officer's failure to record satisfaction or initiate penalty for alleged cash-transaction violations of section 269SS. It requires both an erroneous assessment order and prejudice to Revenue. Penalty under section 271D is independent of assessment proceedings and, under the applicable statutory scheme, falls within the Joint Commissioner's competence. The limitation governing that penalty cannot be bypassed by setting aside a completed assessment to create a fresh penalty foundation, particularly where the underlying transactions admit two plausible views.
Revision under section 263 cannot rest solely on an Assessing Officer's failure to record satisfaction or initiate penalty for alleged cash-transaction violations of section 269SS. It requires both an erroneous assessment order and prejudice to Revenue. Penalty under section 271D is independent of assessment proceedings and, under the applicable statutory scheme, falls within the Joint Commissioner's competence. The limitation governing that penalty cannot be bypassed by setting aside a completed assessment to create a fresh penalty foundation, particularly where the underlying transactions admit two plausible views.
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TaxTMI 
TaxTMI 
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