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...
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Stay of demand - payment of 20% of the outstanding demand - ITAT rejecting its application for stay on the recovery of demand during the pendency of appeal - The Delhi High Court dismissed the petition challenging the ITAT's order on the recovery of tax demand from a national political party. The judgment underlines the importance of compliance with statutory requirements, especially timely filing of tax returns and adherence to conditions for receiving donations, to qualify for exemptions. It also highlights the significance of the taxpayer's conduct in seeking relief from tax demands, concluding that the petitioner's lackadaisical approach and failure to engage with the tax authorities in a timely manner undermined its position.
Stay of demand - payment of 20% of the outstanding demand - ITAT rejecting its application for stay on the recovery of demand during the pendency of appeal - The Delhi High Court dismissed the petition challenging the ITAT's order on the recovery of tax demand from a national political party. The judgment underlines the importance of compliance with statutory requirements, especially timely filing of tax returns and adherence to conditions for receiving donations, to qualify for exemptions. It also highlights the significance of the taxpayer's conduct in seeking relief from tax demands, concluding that the petitioner's lackadaisical approach and failure to engage with the tax authorities in a timely manner undermined its position.
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