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...
The HC upheld the transfer order under s.127 of the Income Tax Act, finding no grounds to interfere with the transfer of assessment from Income Tax Officer, Theni to Deputy Commissioner of Income Tax, Central Circle, Kochi. Though the petitioner claimed the order lacked reasoning, the Court determined that no compelling grounds existed to invalidate the transfer, particularly given the search conducted under s.132/132A and applicable CBDT guidelines. The transfer to Central Circle-2, Kochi was justified for coordinated investigation purposes. The Court concluded the impugned order was valid and required no judicial intervention.
The HC upheld the transfer order under s.127 of the Income Tax Act, finding no grounds to interfere with the transfer of assessment from Income Tax Officer, Theni to Deputy Commissioner of Income Tax, Central Circle, Kochi. Though the petitioner claimed the order lacked reasoning, the Court determined that no compelling grounds existed to invalidate the transfer, particularly given the search conducted under s.132/132A and applicable CBDT guidelines. The transfer to Central Circle-2, Kochi was justified for coordinated investigation purposes. The Court concluded the impugned order was valid and required no judicial intervention.
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