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 - whether the excess disputed amount deposited by the petitioner by way of pre-deposit in respect of the first show-cause notice (SCN-1) can be adjusted towards the amount payable by the petitioner in respect of the second show-cause notice (SCN-2) under the SVLDRS. - The contention of the respondents that two separate show-cause notices cannot be clubbed together for the purpose of SVLDRS cannot be accepted especially when the respondents have given the benefits/relief under the SVLDRS in favour of the petitioner in respect of both the show-cause notices. - HC
SVLDRS - whether the excess disputed amount deposited by the petitioner by way of pre-deposit in respect of the first show-cause notice (SCN-1) can be adjusted towards the amount payable by the petitioner in respect of the second show-cause notice (SCN-2) under the SVLDRS. - The contention of the respondents that two separate show-cause notices cannot be clubbed together for the purpose of SVLDRS cannot be accepted especially when the respondents have given the benefits/relief under the SVLDRS in favour of the petitioner in respect of both the show-cause notices. - HC
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