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...
Writ relief against a private cryptocurrency exchange was refused because the dispute was found to be essentially private and commercial, even though many investors were said to be affected. The exchange entities were held not to be State under Article 12, as they were neither created, financed nor controlled by the State, and taxation of virtual digital assets did not change that position. The Court also declined regulatory mandamus and investigation by CBI or SIT. Claims for release of funds and compensation involved disputed facts, proof of loss and quantification, so they were left to civil, consumer or other competent fora. The appeal was dismissed.
Writ relief against a private cryptocurrency exchange was refused because the dispute was found to be essentially private and commercial, even though many investors were said to be affected. The exchange entities were held not to be State under Article 12, as they were neither created, financed nor controlled by the State, and taxation of virtual digital assets did not change that position. The Court also declined regulatory mandamus and investigation by CBI or SIT. Claims for release of funds and compensation involved disputed facts, proof of loss and quantification, so they were left to civil, consumer or other competent fora. The appeal was dismissed.
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