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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The High Court quashed the order denying waiver of interest charged u/s 234C, holding that the Chief Commissioner of Income Tax failed to consider the petitioner's primary submission attributing the inability to correctly estimate income/profits for paying advance tax to the COVID-19 pandemic. The court observed that the impugned order did not address the petitioner's contentions based on cited decisions or the statutory provisions and scheme of the Income Tax Act relied upon. Consequently, the matter was remanded to the Chief Commissioner for fresh consideration of the waiver application on merits, considering the petitioner's submissions and legal position.
The High Court quashed the order denying waiver of interest charged u/s 234C, holding that the Chief Commissioner of Income Tax failed to consider the petitioner's primary submission attributing the inability to correctly estimate income/profits for paying advance tax to the COVID-19 pandemic. The court observed that the impugned order did not address the petitioner's contentions based on cited decisions or the statutory provisions and scheme of the Income Tax Act relied upon. Consequently, the matter was remanded to the Chief Commissioner for fresh consideration of the waiver application on merits, considering the petitioner's submissions and legal position.
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