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...
Breach of principles of natural justice occurred as the petitioner was unaware of proceedings due to non-communication by the consultant entrusted with GST compliances, resulting in an order confirming tax demand due to non-response. Considering the petitioner's inability to participate, an opportunity should be provided to contest the demand on merits. The order is set aside subject to verification of appropriation of Rs. 4,09,604.87 from the petitioner's bank account towards the demand. If not appropriated, the petitioner shall remit 10% of the disputed tax demand within two weeks. The petition is disposed of accordingly.
Breach of principles of natural justice occurred as the petitioner was unaware of proceedings due to non-communication by the consultant entrusted with GST compliances, resulting in an order confirming tax demand due to non-response. Considering the petitioner's inability to participate, an opportunity should be provided to contest the demand on merits. The order is set aside subject to verification of appropriation of Rs. 4,09,604.87 from the petitioner's bank account towards the demand. If not appropriated, the petitioner shall remit 10% of the disputed tax demand within two weeks. The petition is disposed of accordingly.
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TaxTMI 
TaxTMI 
of 4918 
