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...
Benefit of Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 - refusal to accept the manual returns filed - The requirement of electronic filing is further evidenced by the provisions of the SVLDR Scheme, wherein also, it is specified that the declaration under Section 125 of the Act must be filed electronically. Thus, with the advent of information technology and its advancement, the shift from manual filing to electronic filing serves a salutary purpose and this Court cannot in exercise of its jurisdiction under Article 226 of the Constitution of India interfere with such seamless administration under the taxing statutes - HC
Benefit of Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 - refusal to accept the manual returns filed - The requirement of electronic filing is further evidenced by the provisions of the SVLDR Scheme, wherein also, it is specified that the declaration under Section 125 of the Act must be filed electronically. Thus, with the advent of information technology and its advancement, the shift from manual filing to electronic filing serves a salutary purpose and this Court cannot in exercise of its jurisdiction under Article 226 of the Constitution of India interfere with such seamless administration under the taxing statutes - HC
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