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...
Waiver of interest u/s 234A, 234B and 234C - marginal delay in filing the returns - The petitioner sought relief based on the timing of filing returns after receiving audit reports and financial challenges faced by the cooperative society. - The High Court, after careful consideration of submissions and legal principles, granted partial relief by waiving interest under Section 234A for certain assessment years. However, it refused to grant waivers under Sections 234B and 234C, emphasizing the importance of adhering to statutory timelines for tax payments.
Waiver of interest u/s 234A, 234B and 234C - marginal delay in filing the returns - The petitioner sought relief based on the timing of filing returns after receiving audit reports and financial challenges faced by the cooperative society. - The High Court, after careful consideration of submissions and legal principles, granted partial relief by waiving interest under Section 234A for certain assessment years. However, it refused to grant waivers under Sections 234B and 234C, emphasizing the importance of adhering to statutory timelines for tax payments.
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