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...
Recovery of excise duty, penalty, etc., from the petitioner - fixation of special rate of excise duty - The petitioner has been able to show a prima facie case for hearing because if the requirement of requesting for fixation of a special rate in respect of value addition to the manufactured goods had arisen only after the final judgment of the Supreme Court of India on 22-4-2020, the period of limitation would stand extended for a period of 90 days from 3-10-2021 and therefore, the application which was submitted on 20-10-2021 by the petitioner was well within the period of limitation. Therefore, the balance of convenience tilts in favour of interim protection to the petitioner. - HC
Recovery of excise duty, penalty, etc., from the petitioner - fixation of special rate of excise duty - The petitioner has been able to show a prima facie case for hearing because if the requirement of requesting for fixation of a special rate in respect of value addition to the manufactured goods had arisen only after the final judgment of the Supreme Court of India on 22-4-2020, the period of limitation would stand extended for a period of 90 days from 3-10-2021 and therefore, the application which was submitted on 20-10-2021 by the petitioner was well within the period of limitation. Therefore, the balance of convenience tilts in favour of interim protection to the petitioner. - HC
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TaxTMI 
TaxTMI 
of 4918 
