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...
Delay of 14 years in adjudication of SCN - Assessee was not knowing that matter was put in the call book - Authorization of Directorate of Revenue Intelligence (DRI) to act as a proper officer - It is at once clear that the period within which the impugned show cause notice was required to be adjudicated has long since elapsed. - Since the period for adjudication of the impugned show cause notice has elapsed, the same cannot be adjudicated. - HC
Delay of 14 years in adjudication of SCN - Assessee was not knowing that matter was put in the call book - Authorization of Directorate of Revenue Intelligence (DRI) to act as a proper officer - It is at once clear that the period within which the impugned show cause notice was required to be adjudicated has long since elapsed. - Since the period for adjudication of the impugned show cause notice has elapsed, the same cannot be adjudicated. - HC
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