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...
Maintainability of appeal - appeal rejected on the ground of time limitation - It is undisputed fact on record that as the petitioner has received the order of cancellation of registration on 5th December, 2019, the last date for filing of appeal was 4th April, 2020 but the appeal being filed on 13th April, 2021, the appeal should have been treated as filed within the period of limitation in view of Category-III specified in the Order of the Hon’ble Apex Court - HC
Maintainability of appeal - appeal rejected on the ground of time limitation - It is undisputed fact on record that as the petitioner has received the order of cancellation of registration on 5th December, 2019, the last date for filing of appeal was 4th April, 2020 but the appeal being filed on 13th April, 2021, the appeal should have been treated as filed within the period of limitation in view of Category-III specified in the Order of the Hon’ble Apex Court - HC
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