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...
Opportunity for extension for filing response to the show cause denied = Recovery of Tax Dues - Consideration for rejection of an application for extension was that more than six adjournments were granted - The High court found that the proper officer was obliged to consider the petitioner's application for extension and should not have passed the final order without doing so. - The court held that the failure to grant an extension and offer a personal hearing despite the petitioner showing sufficient cause amounted to a violation of natural justice. - The court quashed the recovery notice issued by the respondents, directing the petitioner to file its response to the show cause notice and ordering the respondents to communicate the date of personal hearing.
Opportunity for extension for filing response to the show cause denied = Recovery of Tax Dues - Consideration for rejection of an application for extension was that more than six adjournments were granted - The High court found that the proper officer was obliged to consider the petitioner's application for extension and should not have passed the final order without doing so. - The court held that the failure to grant an extension and offer a personal hearing despite the petitioner showing sufficient cause amounted to a violation of natural justice. - The court quashed the recovery notice issued by the respondents, directing the petitioner to file its response to the show cause notice and ordering the respondents to communicate the date of personal hearing.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
