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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Re-Determination of refund and interest thereon - Subsequent to the direction of the High Court, revised assessment order was passed, refund and interest amount was re-determined - The High Court noted that despite initial directions from the court to refund the excess amount with interest, the petitioner failed to comply with notices, resulting in revised and rectified assessments. The court ultimately dismissed the writ petition. The petitioner was advised to pursue remedies available under the statute, and the court clarified its limited role in adjudicating such disputes.
Re-Determination of refund and interest thereon - Subsequent to the direction of the High Court, revised assessment order was passed, refund and interest amount was re-determined - The High Court noted that despite initial directions from the court to refund the excess amount with interest, the petitioner failed to comply with notices, resulting in revised and rectified assessments. The court ultimately dismissed the writ petition. The petitioner was advised to pursue remedies available under the statute, and the court clarified its limited role in adjudicating such disputes.
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