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...
The High Court rejected settlement applications by appellants for suppressing income, following the demise of the original assessee. The Settlement Commission found shortcomings in income disclosure, including lack of details on foreign accounts, investments, and business activities. The Commission observed non-cooperation in explaining transactions, leading to rejection of settlements. The Court upheld the Commission's decision, stating that factual findings should not be interfered with unless there is a clear error. Restraint was advised in challenging the Commission's order. The writ petitions filed by the appellants were dismissed by the Court.
The High Court rejected settlement applications by appellants for suppressing income, following the demise of the original assessee. The Settlement Commission found shortcomings in income disclosure, including lack of details on foreign accounts, investments, and business activities. The Commission observed non-cooperation in explaining transactions, leading to rejection of settlements. The Court upheld the Commission's decision, stating that factual findings should not be interfered with unless there is a clear error. Restraint was advised in challenging the Commission's order. The writ petitions filed by the appellants were dismissed by the Court.
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TaxTMI 
TaxTMI 
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