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...
Condonation of delay in filing appeal - three months prescribed period and one month condonable period - Hon'ble Supreme Court has made it clear that what was extended by order of Hon'ble Supreme Court qua Covid-19 period was only the period of limitation and not the period upto which the delay can be condoned in exercise of discretion conferred by the Statute. Therefore, this Court in the light of the authoritative pronouncement of Hon'ble Supreme Court, finds no grounds to interfere with the order of the first respondent. - HC
Condonation of delay in filing appeal - three months prescribed period and one month condonable period - Hon'ble Supreme Court has made it clear that what was extended by order of Hon'ble Supreme Court qua Covid-19 period was only the period of limitation and not the period upto which the delay can be condoned in exercise of discretion conferred by the Statute. Therefore, this Court in the light of the authoritative pronouncement of Hon'ble Supreme Court, finds no grounds to interfere with the order of the first respondent. - HC
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