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...
Territorial Jurisdiction - seeking transfer of place of investigation - The petitioner cited inconvenience due to the distance between their headquarters in Thiruvananthapuram and the location of the investigation in Kasaragod. However, the court found no compelling reason to grant the transfer, noting that Kasaragod is within the boundaries of Kerala. Consequently, the court dismissed this plea. - On the matter of expediting the advance ruling application, the court noted that the application was relatively recent, filed in January 2024. Therefore, the court declined to intervene and compel the advance ruling authority to expedite the decision.
Territorial Jurisdiction - seeking transfer of place of investigation - The petitioner cited inconvenience due to the distance between their headquarters in Thiruvananthapuram and the location of the investigation in Kasaragod. However, the court found no compelling reason to grant the transfer, noting that Kasaragod is within the boundaries of Kerala. Consequently, the court dismissed this plea. - On the matter of expediting the advance ruling application, the court noted that the application was relatively recent, filed in January 2024. Therefore, the court declined to intervene and compel the advance ruling authority to expedite the decision.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
