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...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
Prohibition Benami Property Transactions - change of the Adjudicating Authority - The Court further finds its unable to either countenance or discern an indefeasible right which may be recognised in law as inhering in the petitioners to seek continuance of the authority who had heard the matter on 16 September 2021 despite the appointment of Mr. Sanjog Kapoor in October 2021. Once that officer came to be appointed as the competent authority for SAFEMA, he statutorily and by operation of law also became the Adjudicating Authority for the purposes of the 1988 Act. - HC
Prohibition Benami Property Transactions - change of the Adjudicating Authority - The Court further finds its unable to either countenance or discern an indefeasible right which may be recognised in law as inhering in the petitioners to seek continuance of the authority who had heard the matter on 16 September 2021 despite the appointment of Mr. Sanjog Kapoor in October 2021. Once that officer came to be appointed as the competent authority for SAFEMA, he statutorily and by operation of law also became the Adjudicating Authority for the purposes of the 1988 Act. - HC
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