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 HC dismissed the petition on the ground that efficacious alternative statutory remedies of appeal were available to the petitioner. Freezing of the petitioner's bank account did not violate principles of natural justice as it would not affect the petitioner's ability to institute an appeal by making the pre-deposit. The HC relied on precedents like Oberoi Constructions Ltd and Greatship (India) Limited, which emphasized exhaustion of statutory appellate remedies before entertaining writ petitions, especially in cases involving factual inquiries or classification disputes. The HC noted the tendency to bypass statutory remedies and held that general averments cannot justify bypassing such remedies. The petition was dismissed, and the petitioner was relegated to the alternative remedy of appeal before the Appellate Authority.
The HC dismissed the petition on the ground that efficacious alternative statutory remedies of appeal were available to the petitioner. Freezing of the petitioner's bank account did not violate principles of natural justice as it would not affect the petitioner's ability to institute an appeal by making the pre-deposit. The HC relied on precedents like Oberoi Constructions Ltd and Greatship (India) Limited, which emphasized exhaustion of statutory appellate remedies before entertaining writ petitions, especially in cases involving factual inquiries or classification disputes. The HC noted the tendency to bypass statutory remedies and held that general averments cannot justify bypassing such remedies. The petition was dismissed, and the petitioner was relegated to the alternative remedy of appeal before the Appellate Authority.
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