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...
Refund claim - Unjust enrichment - CA certificate - Merely because the certificate is not as per the liking of the authorities below, it cannot be brushed aside as no specific format of certificate has been prescribed by the statute. If the department proves anything contrary to the statement mentioned in the certificate then certainly they have a valid ground to discard it, but this is not the case anywhere. - AT
Refund claim - Unjust enrichment - CA certificate - Merely because the certificate is not as per the liking of the authorities below, it cannot be brushed aside as no specific format of certificate has been prescribed by the statute. If the department proves anything contrary to the statement mentioned in the certificate then certainly they have a valid ground to discard it, but this is not the case anywhere. - AT
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