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 determined that DRAT erred in remanding the matter to DRT for fresh consideration of jurisdiction and debt status under Section 2(g) of the Recovery of Debts and Bankruptcy Act, 1993. The DRAT failed to fulfill its appellate authority role by not addressing substantive legal issues raised before it, despite having sufficient factual material to decide HDFC's claims against Ashima and BBK. The court emphasized that remand orders should not be issued lightly, particularly in cases pending for nearly 20 years. The HC directed DRAT to decide the appeals on merits without further remand to DRT, noting that remand is only justified when re-trial is necessary or evidence is insufficient for disposition.
The HC determined that DRAT erred in remanding the matter to DRT for fresh consideration of jurisdiction and debt status under Section 2(g) of the Recovery of Debts and Bankruptcy Act, 1993. The DRAT failed to fulfill its appellate authority role by not addressing substantive legal issues raised before it, despite having sufficient factual material to decide HDFC's claims against Ashima and BBK. The court emphasized that remand orders should not be issued lightly, particularly in cases pending for nearly 20 years. The HC directed DRAT to decide the appeals on merits without further remand to DRT, noting that remand is only justified when re-trial is necessary or evidence is insufficient for disposition.
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