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...
Revisional limitation for a Debenture Redemption Reserve adjustment to book profit runs from the original assessment where reassessment was initiated on unrelated financial transactions. The High Court held that the original assessment continues to govern matters not forming part of reassessment, while the reassessment order supersedes it only for reassessed items. Although Explanation 3 permits assessment of another escaped-income issue noticed during reassessment, the DRR issue was not shown to have arisen then. The revisional order was therefore time-barred and set aside; the merits of the DRR adjustment remained open.
Revisional limitation for a Debenture Redemption Reserve adjustment to book profit runs from the original assessment where reassessment was initiated on unrelated financial transactions. The High Court held that the original assessment continues to govern matters not forming part of reassessment, while the reassessment order supersedes it only for reassessed items. Although Explanation 3 permits assessment of another escaped-income issue noticed during reassessment, the DRR issue was not shown to have arisen then. The revisional order was therefore time-barred and set aside; the merits of the DRR adjustment remained open.
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TaxTMI 
TaxTMI 
of 4918 
