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...
Refusal of request for Extension of due date for filing income tax returns for the assessment year 2020-21 - Power exercised by the CBDT under section 119 of the Act is discretionary. On careful consideration of the order passed by the CBDT on 11th January, 2021 under the said provision, we are of the considered view that it cannot be said that CBDT had failed to exercise its discretion or that CBDT had acted in an arbitrary or unreasonable manner in refusing to grant further extension of the due dates. - HC
Refusal of request for Extension of due date for filing income tax returns for the assessment year 2020-21 - Power exercised by the CBDT under section 119 of the Act is discretionary. On careful consideration of the order passed by the CBDT on 11th January, 2021 under the said provision, we are of the considered view that it cannot be said that CBDT had failed to exercise its discretion or that CBDT had acted in an arbitrary or unreasonable manner in refusing to grant further extension of the due dates. - HC
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