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 dismissed the review petition against its order that had remitted the case for fresh assessment. The court found no grounds for review as the original order was based on a concession by the review petitioner's counsel and the remittance was in accordance with Supreme Court precedent. The petitioner's argument regarding the inapplicability of the proviso to Section 2(15) to their case could not be entertained under review jurisdiction. The court relied on precedents established in Sanjay Kumar Agarwal v. State Tax Officer (1) & Anr. and Rimpa Saha to determine that the case did not fall within the limited scope of review powers.
HC dismissed the review petition against its order that had remitted the case for fresh assessment. The court found no grounds for review as the original order was based on a concession by the review petitioner's counsel and the remittance was in accordance with Supreme Court precedent. The petitioner's argument regarding the inapplicability of the proviso to Section 2(15) to their case could not be entertained under review jurisdiction. The court relied on precedents established in Sanjay Kumar Agarwal v. State Tax Officer (1) & Anr. and Rimpa Saha to determine that the case did not fall within the limited scope of review powers.
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