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...
Writ petitions seeking recovery of contractual deductions may be barred by limitation where each deduction creates a separate cause of action. The article explains that limitation for a recovery suit runs from the date of each deduction, rather than contract completion, where monthly invoices and payments do not establish a running account; pandemic-related limitation extensions cannot revive already time-barred claims. Invoking Article 226 cannot circumvent limitation, delay, or laches. It further notes that purely monetary contractual disputes involving disputed facts and requiring evidence should ordinarily be pursued through a civil suit. Accordingly, such refund claims are described as not maintainable in writ jurisdiction and liable to dismissal.
Writ petitions seeking recovery of contractual deductions may be barred by limitation where each deduction creates a separate cause of action. The article explains that limitation for a recovery suit runs from the date of each deduction, rather than contract completion, where monthly invoices and payments do not establish a running account; pandemic-related limitation extensions cannot revive already time-barred claims. Invoking Article 226 cannot circumvent limitation, delay, or laches. It further notes that purely monetary contractual disputes involving disputed facts and requiring evidence should ordinarily be pursued through a civil suit. Accordingly, such refund claims are described as not maintainable in writ jurisdiction and liable to dismissal.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
