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 writ petition - The High court held that the 1st respondent company, being a Public Sector Undertaking with the majority of its shares held by government entities and subject to significant government control, qualifies as an "instrumentality of the Union of India" under Article 12 of the Constitution. Therefore, it is amenable to writ jurisdiction, overturning the previous judgment that deemed the writ petition not maintainable.
Maintainability of writ petition - The High court held that the 1st respondent company, being a Public Sector Undertaking with the majority of its shares held by government entities and subject to significant government control, qualifies as an "instrumentality of the Union of India" under Article 12 of the Constitution. Therefore, it is amenable to writ jurisdiction, overturning the previous judgment that deemed the writ petition not maintainable.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
