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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Non-forwarding of bills by user departments for scrutiny and delay in uploading soft copies led to rejection of discharge application. However, the material presented by CBI fell short of substantiating the accusations against the petitioners. Absence of prosecution against public servants raised doubts about CBI's ability to prosecute petitioners, as per the Delhi High Court's ruling that dropping charges against the main public servant precludes charges of abetment. No grave suspicion was established based on available evidence. Continuing prosecution would be an abuse of legal process with no chance of conviction. The High Court set aside the lower court's order and discharged the petitioners.
Non-forwarding of bills by user departments for scrutiny and delay in uploading soft copies led to rejection of discharge application. However, the material presented by CBI fell short of substantiating the accusations against the petitioners. Absence of prosecution against public servants raised doubts about CBI's ability to prosecute petitioners, as per the Delhi High Court's ruling that dropping charges against the main public servant precludes charges of abetment. No grave suspicion was established based on available evidence. Continuing prosecution would be an abuse of legal process with no chance of conviction. The High Court set aside the lower court's order and discharged the petitioners.
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