Centralised assessment transfers after searches coordinate connected investigations without finally determining the assessee's tax liability or assess...
Unsigned third-party records cannot establish on-money payments without corroboration and cross-examination, requiring deletion of the related additio...
Reassessment based solely on transfer-pricing material already examined in scrutiny proceedings is impermissible where the earlier assessment lapsed because no final order followed the draft assessment order within the prescribed period. Without fresh material, reopening would circumvent the statutory time limit for completing assessment and allow the Revenue to benefit from its own omission. The reassessment notices and the order under section 148A(3) were quashed, and the writ petition was allowed.
Reassessment based solely on transfer-pricing material already examined in scrutiny proceedings is impermissible where the earlier assessment lapsed because no final order followed the draft assessment order within the prescribed period. Without fresh material, reopening would circumvent the statutory time limit for completing assessment and allow the Revenue to benefit from its own omission. The reassessment notices and the order under section 148A(3) were quashed, and the writ petition was allowed.
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