Only Embedded Profit Counts for Extended Reassessment Limits, Rendering Third-Party Reassessment Invalid Without Cross-Examination
Only Embedded Profit Counts for Extended Reassessment Limits, Rendering Third-Party Reassessment Invalid Without Cross-Examination Issue Whether reassessment notices issued under Section 148 beyond the three-year limit based on third-party seized data (“Sanjeev Tally”) are valid when the estimated escaped income (embedded profit element) is below Rs. 50 lakhs per assessment year. Whether third-party digital records… Read More »