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...
The HC held that the four-year limitation period u/s 64 of the Karnataka Value Added Tax Act, 2003, pertains to the initiation of revisional proceedings by the Additional Commissioner and not the passing of the final order. In the instant case, the revisional proceedings were initiated within the four-year period from the original order's date, and thus, the Additional Commissioner had jurisdiction to pass the revisional order, even after the expiry of four years from the original order.
The HC held that the four-year limitation period u/s 64 of the Karnataka Value Added Tax Act, 2003, pertains to the initiation of revisional proceedings by the Additional Commissioner and not the passing of the final order. In the instant case, the revisional proceedings were initiated within the four-year period from the original order's date, and thus, the Additional Commissioner had jurisdiction to pass the revisional order, even after the expiry of four years from the original order.
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TaxTMI 
TaxTMI 
of 4918 
