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...
SVLDRS - Eligibility of the declarant for making a declaration under the category of ‘investigation, enquiry or audit’ - acknowledgment or admission by the petitioner was before the cut-off date of 30.06.2019. - Though the final audit report may be post 30.06.2019, the admission of the petitioner was certainly prior to 30.06.2019 - rejection of the declaration of the petitioner dated 02.12.2019 by the designated committee on 12.02.2020 is not justified. - HC
SVLDRS - Eligibility of the declarant for making a declaration under the category of ‘investigation, enquiry or audit’ - acknowledgment or admission by the petitioner was before the cut-off date of 30.06.2019. - Though the final audit report may be post 30.06.2019, the admission of the petitioner was certainly prior to 30.06.2019 - rejection of the declaration of the petitioner dated 02.12.2019 by the designated committee on 12.02.2020 is not justified. - HC
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