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...
HC upheld assessment order issued under Section 143(3) read with 144B, finding no violation of natural justice principles. The assessee had received show cause notice and participated in video conferencing hearing, where they explained loan transactions in detail. The Court determined video conferencing was substantive, not merely procedural. Notably, assessee failed to produce relevant documentation supporting their position despite having opportunity. Court emphasized that burden lies with notice recipient to furnish supporting evidence, and assessing officer cannot be expected to specifically request unknown documents. Finding due process requirements satisfied and no procedural violations established, petition dismissed.
HC upheld assessment order issued under Section 143(3) read with 144B, finding no violation of natural justice principles. The assessee had received show cause notice and participated in video conferencing hearing, where they explained loan transactions in detail. The Court determined video conferencing was substantive, not merely procedural. Notably, assessee failed to produce relevant documentation supporting their position despite having opportunity. Court emphasized that burden lies with notice recipient to furnish supporting evidence, and assessing officer cannot be expected to specifically request unknown documents. Finding due process requirements satisfied and no procedural violations established, petition dismissed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
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