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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Determination of time limit for filing of Appeal before the Appellate Authority - Delay due to the online system's failure to upload the Order-in-Original with the appeal. - Condonation of delay - The High Court found that the appeal was filed within the three-month limitation period, contrary to the Appellate Authority's ruling. The Court noted that the Order-in-Original was indeed uploaded with the appeal, contrary to the earlier technical glitch claimed by the respondents. The High Court upheld the petitioner's argument regarding the interpretation of Rule 108(3) and deemed the appeal filed on the date of online submission, i.e., 12.11.2022. In applying Section 12 of the Limitation Act, the Court excluded certain periods, ultimately concluding that the appeal was within the limitation period.
Determination of time limit for filing of Appeal before the Appellate Authority - Delay due to the online system's failure to upload the Order-in-Original with the appeal. - Condonation of delay - The High Court found that the appeal was filed within the three-month limitation period, contrary to the Appellate Authority's ruling. The Court noted that the Order-in-Original was indeed uploaded with the appeal, contrary to the earlier technical glitch claimed by the respondents. The High Court upheld the petitioner's argument regarding the interpretation of Rule 108(3) and deemed the appeal filed on the date of online submission, i.e., 12.11.2022. In applying Section 12 of the Limitation Act, the Court excluded certain periods, ultimately concluding that the appeal was within the limitation period.
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