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...
A review order restoring pending appeals was treated as a consequence of the liberty expressly reserved in the earlier appellate order and of the Supreme Court's recall of the binding precedent. The HC held that, where the Tribunal allowed review and restored the appeals in terms of that liberty, the appellants could not challenge the restoration by disputing review power or limitation. It further held that an order granting review and reviving the main appeal is interlocutory and not independently appealable, because the CPC applies to the Tribunal and the bar in Order 47 Rule 7 CPC operates against an appeal from such a review order. The appeals were dismissed as not maintainable.
A review order restoring pending appeals was treated as a consequence of the liberty expressly reserved in the earlier appellate order and of the Supreme Court's recall of the binding precedent. The HC held that, where the Tribunal allowed review and restored the appeals in terms of that liberty, the appellants could not challenge the restoration by disputing review power or limitation. It further held that an order granting review and reviving the main appeal is interlocutory and not independently appealable, because the CPC applies to the Tribunal and the bar in Order 47 Rule 7 CPC operates against an appeal from such a review order. The appeals were dismissed as not maintainable.
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