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...
Order u/s 119(2)(b) of the Act rejecting the application for waiver of time limit for filing of the return - claim in the refund on account of the tax deducted at source from the income of late father - The Court noted that the PCIT's rejection was contrary to established legal principles. Referring to precedents, the Court emphasized the need for a liberal interpretation of "genuine hardship" and justice-oriented approach in such matters. The High Court held that the petition succeeds and is accordingly allowed.
Order u/s 119(2)(b) of the Act rejecting the application for waiver of time limit for filing of the return - claim in the refund on account of the tax deducted at source from the income of late father - The Court noted that the PCIT's rejection was contrary to established legal principles. Referring to precedents, the Court emphasized the need for a liberal interpretation of "genuine hardship" and justice-oriented approach in such matters. The High Court held that the petition succeeds and is accordingly allowed.
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