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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Benami transaction - possession of a significant amount of cash - Validity of summoning order - The High Court found merit in the applicant's arguments, emphasizing the lack of sufficient grounds for prosecution under Section 53 of the PBPT Act. It noted the absence of allegations regarding the intention to defeat legal provisions or evade dues in the complaint, rendering the summoning order devoid of legal basis. Emphasizing the seriousness of summoning an accused, the Court granted interim relief, staying further proceedings pending full consideration of the matter.
Benami transaction - possession of a significant amount of cash - Validity of summoning order - The High Court found merit in the applicant's arguments, emphasizing the lack of sufficient grounds for prosecution under Section 53 of the PBPT Act. It noted the absence of allegations regarding the intention to defeat legal provisions or evade dues in the complaint, rendering the summoning order devoid of legal basis. Emphasizing the seriousness of summoning an accused, the Court granted interim relief, staying further proceedings pending full consideration of the matter.
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