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...
Scope of SCN - impugned order proceeds on a completely different basis from the SCN - Entitlement to ITC - The High Court observed a clear disparity between the initial show cause notice and the final order. While the notice alleged sales suppression and proposed a specific tax liability, the order imposed a significantly higher amount without justification. Notably, the impugned order did not rely on sales suppression as a basis for its decision, raising questions about the rationale behind the increased tax liability. Consequently, the Court set aside the impugned order.
Scope of SCN - impugned order proceeds on a completely different basis from the SCN - Entitlement to ITC - The High Court observed a clear disparity between the initial show cause notice and the final order. While the notice alleged sales suppression and proposed a specific tax liability, the order imposed a significantly higher amount without justification. Notably, the impugned order did not rely on sales suppression as a basis for its decision, raising questions about the rationale behind the increased tax liability. Consequently, the Court set aside the impugned order.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4921 
