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 dismissed writ petition challenging reassessment proceedings under Section 147. Court declined jurisdiction noting petitioner's failure to raise TOLA provisions applicability in initial objections, making it inappropriate to address first time in writ. Questions about Section 54F deductions and rental income taxation involved factual determinations unsuitable for writ jurisdiction. While audit-based reopening was contested, Court held distinction between fact-based and law-based audit objections requires factual examination. Petitioner's participation in proceedings without timely objections weakened procedural challenges. Court granted 4-week extension of interim relief for appeal filing and stay application, directing appellate authority to consider all grounds including procedural objections.
HC dismissed writ petition challenging reassessment proceedings under Section 147. Court declined jurisdiction noting petitioner's failure to raise TOLA provisions applicability in initial objections, making it inappropriate to address first time in writ. Questions about Section 54F deductions and rental income taxation involved factual determinations unsuitable for writ jurisdiction. While audit-based reopening was contested, Court held distinction between fact-based and law-based audit objections requires factual examination. Petitioner's participation in proceedings without timely objections weakened procedural challenges. Court granted 4-week extension of interim relief for appeal filing and stay application, directing appellate authority to consider all grounds including procedural objections.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4921 
