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...
The High Court held that the Interim Board for Settlement erred in rejecting the petitioner's settlement application for the relevant assessment years based on the condition in the CBDT notification that the assessee should be eligible on January 21, 2021. The court relied on its previous decision in Sar Senapati Santaji Ghorpade Sugar Factory Ltd., which quashed the said condition as ultra vires Section 119. Following this precedent and its recent decision in M/s. Vishwakarma Developers, the court allowed the present proceedings and quashed the orders passed by the Interim Settlement Board rejecting the petitioner's application.
The High Court held that the Interim Board for Settlement erred in rejecting the petitioner's settlement application for the relevant assessment years based on the condition in the CBDT notification that the assessee should be eligible on January 21, 2021. The court relied on its previous decision in Sar Senapati Santaji Ghorpade Sugar Factory Ltd., which quashed the said condition as ultra vires Section 119. Following this precedent and its recent decision in M/s. Vishwakarma Developers, the court allowed the present proceedings and quashed the orders passed by the Interim Settlement Board rejecting the petitioner's application.
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