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...
HC granted relief to petitioner seeking condonation of delay in filing revised income tax return under s.139(5). Court considered multiple factors including director's personal circumstances (family issues, mother's illness requiring spine surgeries), company's operational challenges (ERP implementation, high staff attrition), and management's inability to detect incorrect figures until s.142(1) notice. Finding these human factors and fortuitous circumstances compelling, HC quashed original order dated 21/09/2023. Respondents directed to accept returns with applicable penalties, fees and interest within two weeks of order copy availability. Court emphasized necessity of considering human elements when evaluating statutory time limit compliance under IT Act.
HC granted relief to petitioner seeking condonation of delay in filing revised income tax return under s.139(5). Court considered multiple factors including director's personal circumstances (family issues, mother's illness requiring spine surgeries), company's operational challenges (ERP implementation, high staff attrition), and management's inability to detect incorrect figures until s.142(1) notice. Finding these human factors and fortuitous circumstances compelling, HC quashed original order dated 21/09/2023. Respondents directed to accept returns with applicable penalties, fees and interest within two weeks of order copy availability. Court emphasized necessity of considering human elements when evaluating statutory time limit compliance under IT Act.
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