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 expressed concerns over the Revenue's representative's contradictory statements regarding the availability of test reports issued by IRMRA during the main appeal hearing and the subsequent rectification application hearing before the Tribunal. The Court directed the Joint Chief Department Representative, Mumbai Bench CESTAT, to conduct a detailed inquiry into how such an incident occurred, identify the responsible individuals, and report to the Court on the disciplinary actions taken or proposed against those from the Revenue Department, as well as any actions against private individuals involved. The Court emphasized the seriousness of the matter, considering the high financial stakes and the series of appellants before the Tribunal.
The High Court expressed concerns over the Revenue's representative's contradictory statements regarding the availability of test reports issued by IRMRA during the main appeal hearing and the subsequent rectification application hearing before the Tribunal. The Court directed the Joint Chief Department Representative, Mumbai Bench CESTAT, to conduct a detailed inquiry into how such an incident occurred, identify the responsible individuals, and report to the Court on the disciplinary actions taken or proposed against those from the Revenue Department, as well as any actions against private individuals involved. The Court emphasized the seriousness of the matter, considering the high financial stakes and the series of appellants before the Tribunal.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
