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...
Information indicating income escaping assessment must relate to the same assessment year proposed for reopening. Reassessment for AY 2020-21 could not rest on agricultural-land sale information from FY 2020-21, which related to AY 2021-22 rather than FY 2019-20. Because the transaction had no bearing on income for AY 2020-21, it could not establish escapement for that year. The reassessment notices, initiating order and consequential proceedings were quashed.
Information indicating income escaping assessment must relate to the same assessment year proposed for reopening. Reassessment for AY 2020-21 could not rest on agricultural-land sale information from FY 2020-21, which related to AY 2021-22 rather than FY 2019-20. Because the transaction had no bearing on income for AY 2020-21, it could not establish escapement for that year. The reassessment notices, initiating order and consequential proceedings were quashed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
