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 quashed the criminal proceedings and cognizance orders against the petitioners for offenses u/ss 276B and 278B of the Income Tax Act. The TDS amount in question, which was the subject matter of the economic offense cases and C.O. Case, had already been deposited belatedly with interest to the Income Tax Department. The court held that continuing the proceedings would amount to an abuse of the process of law, given the deposit of the TDS amount and the amendment made to Section 276B in the Finance Act, 2024, allowing such delayed deposits. Consequently, the cognizance orders passed by the Special Judge, Economic Offenses, against the petitioners were quashed.
The High Court quashed the criminal proceedings and cognizance orders against the petitioners for offenses u/ss 276B and 278B of the Income Tax Act. The TDS amount in question, which was the subject matter of the economic offense cases and C.O. Case, had already been deposited belatedly with interest to the Income Tax Department. The court held that continuing the proceedings would amount to an abuse of the process of law, given the deposit of the TDS amount and the amendment made to Section 276B in the Finance Act, 2024, allowing such delayed deposits. Consequently, the cognizance orders passed by the Special Judge, Economic Offenses, against the petitioners were quashed.
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