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...
The HC quashed a tax revision notice issued under section 263 against a dissolved company. The court held that the approved Resolution Plan had explicitly extinguished all tax liabilities of the Corporate Debtor for periods prior to NCLT approval on 12.10.2023. Relying on Essar and Edelweiss Supreme Court precedents, the court determined that once the Resolution Plan extinguished all tax liabilities, there was no legal basis for authorities to issue revision notices for Assessment Year 2015-16. The petition was allowed and the impugned notice dated 13.01.2025 was set aside as the question of its merits had become academic.
The HC quashed a tax revision notice issued under section 263 against a dissolved company. The court held that the approved Resolution Plan had explicitly extinguished all tax liabilities of the Corporate Debtor for periods prior to NCLT approval on 12.10.2023. Relying on Essar and Edelweiss Supreme Court precedents, the court determined that once the Resolution Plan extinguished all tax liabilities, there was no legal basis for authorities to issue revision notices for Assessment Year 2015-16. The petition was allowed and the impugned notice dated 13.01.2025 was set aside as the question of its merits had become academic.
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