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 held that revisional authority's refusal to exercise jurisdiction under Section 264 was legally untenable. The authority's reasoning that revision was not maintainable because order was appealable and assessee had not filed appeal was contrary to law. Further, the authority's position that intimation under Section 143(1) was not amenable to revision jurisdiction was incorrect, as established in multiple precedents. The court set aside the impugned order dated February 12, 2021, finding both grounds for declining jurisdiction unsustainable. The revision petition was restored to be decided on merits by the revisional authority in accordance with law.
HC held that revisional authority's refusal to exercise jurisdiction under Section 264 was legally untenable. The authority's reasoning that revision was not maintainable because order was appealable and assessee had not filed appeal was contrary to law. Further, the authority's position that intimation under Section 143(1) was not amenable to revision jurisdiction was incorrect, as established in multiple precedents. The court set aside the impugned order dated February 12, 2021, finding both grounds for declining jurisdiction unsustainable. The revision petition was restored to be decided on merits by the revisional authority in accordance with law.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
