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...
Refund of the entire amount on deposit made by the petitioner/assessee - In a case such as this where the refund claim has arisen solely on the strength of the appeal order, unless the assessing authority may plead ignorance of the same, we also cannot remain unmindful of the fact, while rejecting such claims, the authorities are forcing the assessee to litigate and also defeating the claim of interest that is otherwise due on account of delay in processing the refund application. - HC
Refund of the entire amount on deposit made by the petitioner/assessee - In a case such as this where the refund claim has arisen solely on the strength of the appeal order, unless the assessing authority may plead ignorance of the same, we also cannot remain unmindful of the fact, while rejecting such claims, the authorities are forcing the assessee to litigate and also defeating the claim of interest that is otherwise due on account of delay in processing the refund application. - HC
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