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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Liability to pay fine and penalty - The Punjab & Haryana High Court allowed the appeal, quashing the impugned order. The Court emphasized the necessity of proving mens rea for imposing penalties under Section 11AC and ruled that proper reconciliation of records with valid invoices negated the presumption of intent to evade duty. The decision reaffirms the importance of adherence to procedural and evidentiary standards in the imposition of statutory penalties.
Liability to pay fine and penalty - The Punjab & Haryana High Court allowed the appeal, quashing the impugned order. The Court emphasized the necessity of proving mens rea for imposing penalties under Section 11AC and ruled that proper reconciliation of records with valid invoices negated the presumption of intent to evade duty. The decision reaffirms the importance of adherence to procedural and evidentiary standards in the imposition of statutory penalties.
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