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...
Rejection of Application under the DTVSV Act 2020 - whether no appeal is pending as on the date specified date i.e. 31.01.2020, whereas the appeal was filed with an application for condonation of delay - the rejection of the declaration filed by the petitioner under DTVSV Act, 2020 in Forms 1 and 2 on 05.03.2021. with the ‘Remark’ noted on 20.04.2021, by the 3rd respondent, on the basis of answer to Q.No.59, vide Circular No.21 dated 04.12.2020, cannot be sustained. - HC
Rejection of Application under the DTVSV Act 2020 - whether no appeal is pending as on the date specified date i.e. 31.01.2020, whereas the appeal was filed with an application for condonation of delay - the rejection of the declaration filed by the petitioner under DTVSV Act, 2020 in Forms 1 and 2 on 05.03.2021. with the ‘Remark’ noted on 20.04.2021, by the 3rd respondent, on the basis of answer to Q.No.59, vide Circular No.21 dated 04.12.2020, cannot be sustained. - HC
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