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 court held that the circumstances for issuing a Look-Out Circular (LOC) were not met in the present case. The petitioner was cooperating with the investigating agency by furnishing documents and responding to queries, and had appeared before the Enforcement Directorate (ED) more than 14 times. The Supreme Court had granted anticipatory bail to the petitioner with directions not to take coercive action, including arrest, and obliging the petitioner to join the investigation when called upon. Given that the petitioner had joined the investigations, was not evading the process of law, and there was no likelihood of leaving the country to evade trial, the grounds for continuing the LOC did not exist. Consequently, the LOC issued against the petitioner was quashed.
The court held that the circumstances for issuing a Look-Out Circular (LOC) were not met in the present case. The petitioner was cooperating with the investigating agency by furnishing documents and responding to queries, and had appeared before the Enforcement Directorate (ED) more than 14 times. The Supreme Court had granted anticipatory bail to the petitioner with directions not to take coercive action, including arrest, and obliging the petitioner to join the investigation when called upon. Given that the petitioner had joined the investigations, was not evading the process of law, and there was no likelihood of leaving the country to evade trial, the grounds for continuing the LOC did not exist. Consequently, the LOC issued against the petitioner was quashed.
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