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...
Reassessment founded on misstated facts, mechanically adopted investigation inputs, and transactions already examined in scrutiny constitutes an impermissible change of opinion and is invalid. Section 69A does not apply to recorded equity-share purchases where contract notes, broker records, and bank evidence establish the source of investment. It also cannot treat accounted sale proceeds of recorded shares as unexplained investment; taxing those proceeds again after the related income has been offered results in double taxation. Failure to verify supporting material or permit cross-examination of a retracted third-party statement further undermines the addition.
Reassessment founded on misstated facts, mechanically adopted investigation inputs, and transactions already examined in scrutiny constitutes an impermissible change of opinion and is invalid. Section 69A does not apply to recorded equity-share purchases where contract notes, broker records, and bank evidence establish the source of investment. It also cannot treat accounted sale proceeds of recorded shares as unexplained investment; taxing those proceeds again after the related income has been offered results in double taxation. Failure to verify supporting material or permit cross-examination of a retracted third-party statement further undermines the addition.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
