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...
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Inter-State transfer of assessment jurisdiction for coordinated investigation requires a demonstrated structural nexus between the taxpayer and the searched group; an isolated transaction is insufficient. Alleged incriminating material must establish interlacing of funds or interconnected business activities, rather than an unfounded or non-transparent conclusion. Absent a legitimate necessity for coordinated investigation, transfer may be arbitrary, show non-application of mind, and breach natural justice. Assessment jurisdiction remained at Kolkata, while material gathered at New Delhi was to be sent to the Kolkata Assessing Officer for lawful inquiry, preserving the Revenue's ability to investigate there.
Inter-State transfer of assessment jurisdiction for coordinated investigation requires a demonstrated structural nexus between the taxpayer and the searched group; an isolated transaction is insufficient. Alleged incriminating material must establish interlacing of funds or interconnected business activities, rather than an unfounded or non-transparent conclusion. Absent a legitimate necessity for coordinated investigation, transfer may be arbitrary, show non-application of mind, and breach natural justice. Assessment jurisdiction remained at Kolkata, while material gathered at New Delhi was to be sent to the Kolkata Assessing Officer for lawful inquiry, preserving the Revenue's ability to investigate there.
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