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...
Inordinate delay of more than 2100 days in filing revisions was not condoned because the revisionists offered no plausible explanation, had absconded after conviction, and had shown disregard for the court process. Despite that, the High Court set aside the non-speaking appellate judgments because the criminal appeals had been decided in the appellants' absence without appointment of amicus curiae and without the required scrutiny of the record and trial court reasoning. Applying the rule in Bani Singh and related authorities, the Court held that such defective disposal could not stand and revived the appeals for fresh hearing on merits, subject to deposit of part of the fine and payment of costs.
Inordinate delay of more than 2100 days in filing revisions was not condoned because the revisionists offered no plausible explanation, had absconded after conviction, and had shown disregard for the court process. Despite that, the High Court set aside the non-speaking appellate judgments because the criminal appeals had been decided in the appellants' absence without appointment of amicus curiae and without the required scrutiny of the record and trial court reasoning. Applying the rule in Bani Singh and related authorities, the Court held that such defective disposal could not stand and revived the appeals for fresh hearing on merits, subject to deposit of part of the fine and payment of costs.
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