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...
Principles of natural justice violated due to lack of proper communication regarding show cause notice and order, leading to tax demand confirmation without petitioner's response. Court set aside the order and remanded matter for reconsideration, subject to petitioner remitting 10% of disputed tax demand within two weeks, acknowledging procedural lapse despite imposing condition. Petition disposed through remand for fresh consideration after partial compliance.
Principles of natural justice violated due to lack of proper communication regarding show cause notice and order, leading to tax demand confirmation without petitioner's response. Court set aside the order and remanded matter for reconsideration, subject to petitioner remitting 10% of disputed tax demand within two weeks, acknowledging procedural lapse despite imposing condition. Petition disposed through remand for fresh consideration after partial compliance.
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