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...
Maintainability of petition - The High court held the principle of self-restraint adopted by constitutional courts in cases where alternative and efficacious remedies are available, leading to the dismissal of the writ petition. The decision highlighted the importance of availing statutory remedies before approaching the court under Article 226 of the Constitution, especially when there are disputes regarding facts or entitlements for exemptions.
Maintainability of petition - The High court held the principle of self-restraint adopted by constitutional courts in cases where alternative and efficacious remedies are available, leading to the dismissal of the writ petition. The decision highlighted the importance of availing statutory remedies before approaching the court under Article 226 of the Constitution, especially when there are disputes regarding facts or entitlements for exemptions.
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