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 rejected the review petition challenging its previous order treating the ITR under Section 139 as "non-est." The Court held that not answering a substantial question regarding the applicability of specific clauses of Section 158-BB did not constitute grounds for review, as this point was left open for the Appellate Tribunal to determine after remand. The Court found no error apparent on the face of the record in its earlier judgment that would justify exercise of review jurisdiction, despite the petitioner's argument about double jeopardy between regular proceedings and block assessment proceedings. The Court distinguished between the scope of review proceedings and statutory appeal, concluding that the effect of its order on subsequent proceedings would be addressed in the connected Income Tax Appeal.
The HC rejected the review petition challenging its previous order treating the ITR under Section 139 as "non-est." The Court held that not answering a substantial question regarding the applicability of specific clauses of Section 158-BB did not constitute grounds for review, as this point was left open for the Appellate Tribunal to determine after remand. The Court found no error apparent on the face of the record in its earlier judgment that would justify exercise of review jurisdiction, despite the petitioner's argument about double jeopardy between regular proceedings and block assessment proceedings. The Court distinguished between the scope of review proceedings and statutory appeal, concluding that the effect of its order on subsequent proceedings would be addressed in the connected Income Tax Appeal.
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