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...
Article 226(2) permits writ jurisdiction where part of the cause of action arises within a court's territory, but its discretionary operation requires consideration of forum conveniens and the principal, substantial nexus. Issuance of an investigation order from Delhi and an affidavit filed by an SFIO officer there did not create a sufficient nexus with Delhi. Mumbai was the appropriate forum because the companies' registered offices and records, the relevant Registrar of Companies, insolvency proceedings, the competent Special Court, and related investigation proceedings were situated there. The writ petition was dismissed for want of territorial jurisdiction, without examining the investigation's merits.
Article 226(2) permits writ jurisdiction where part of the cause of action arises within a court's territory, but its discretionary operation requires consideration of forum conveniens and the principal, substantial nexus. Issuance of an investigation order from Delhi and an affidavit filed by an SFIO officer there did not create a sufficient nexus with Delhi. Mumbai was the appropriate forum because the companies' registered offices and records, the relevant Registrar of Companies, insolvency proceedings, the competent Special Court, and related investigation proceedings were situated there. The writ petition was dismissed for want of territorial jurisdiction, without examining the investigation's merits.
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TaxTMI 
TaxTMI 
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