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...
Validity of Reopening of assessment u/s 147 - it is a well settled position of law that an individual seeking to invoke the equitable jurisdiction of a High Court must approach this Court displaying bona fides. However, in the present case, the Petitioner has unquestionably suppressed material facts in relation to the cancellation of its registration under Section 12A, 12AA and 12AB of the IT Act. - HC
Validity of Reopening of assessment u/s 147 - it is a well settled position of law that an individual seeking to invoke the equitable jurisdiction of a High Court must approach this Court displaying bona fides. However, in the present case, the Petitioner has unquestionably suppressed material facts in relation to the cancellation of its registration under Section 12A, 12AA and 12AB of the IT Act. - HC
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