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...
SC quashed the First Information Report (FIR) against the appellant, holding that a mere breach of commercial agreement does not constitute criminal fraud under Section 415 IPC. The Court found no evidence of deliberate deception, noting the appellant's creditworthiness was demonstrated by bankers' continued financial support, including an additional loan in 2018. The materials collected during investigation did not establish fraudulent intent at the transaction's inception. The Court emphasized that defaulting on a commercial arrangement does not automatically imply criminal intent, distinguishing between civil contractual disputes and criminal offenses. The impugned order was set aside, effectively terminating the criminal proceedings against the appellant.
SC quashed the First Information Report (FIR) against the appellant, holding that a mere breach of commercial agreement does not constitute criminal fraud under Section 415 IPC. The Court found no evidence of deliberate deception, noting the appellant's creditworthiness was demonstrated by bankers' continued financial support, including an additional loan in 2018. The materials collected during investigation did not establish fraudulent intent at the transaction's inception. The Court emphasized that defaulting on a commercial arrangement does not automatically imply criminal intent, distinguishing between civil contractual disputes and criminal offenses. The impugned order was set aside, effectively terminating the criminal proceedings against the appellant.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
