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 ruled on tax settlement scheme interpretation regarding admitted versus disputed tax amounts. Settlement Officer erroneously deducted pre-deposit from disputed amount before applying 60% waiver under scheme. On Rs. 5,94,03,043 disputed amount (difference between determined tax Rs. 6,27,82,418 and admitted tax Rs. 33,79,374), petitioner was entitled to 60% waiver on full disputed sum without pre-deposit adjustment. Court set aside appellate authority's order, directed recalculation of settlement amount without deducting Rs. 49,00,000 pre-deposit from disputed amount before applying waiver. Ordered refund of excess amount with 6% interest per annum from deposit date until refund. Court emphasized liberal interpretation of beneficial tax legislation per precedent.
HC ruled on tax settlement scheme interpretation regarding admitted versus disputed tax amounts. Settlement Officer erroneously deducted pre-deposit from disputed amount before applying 60% waiver under scheme. On Rs. 5,94,03,043 disputed amount (difference between determined tax Rs. 6,27,82,418 and admitted tax Rs. 33,79,374), petitioner was entitled to 60% waiver on full disputed sum without pre-deposit adjustment. Court set aside appellate authority's order, directed recalculation of settlement amount without deducting Rs. 49,00,000 pre-deposit from disputed amount before applying waiver. Ordered refund of excess amount with 6% interest per annum from deposit date until refund. Court emphasized liberal interpretation of beneficial tax legislation per precedent.
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TaxTMI 
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