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...
HC determined that the petitioner's declaration under SABKA VISHWAS (Legacy Dispute Resolution) Scheme, 2019 was invalid. The court found the declaration under "arrears category" contradictory, as the petitioner deliberately misled the system by filing incorrect tax details. The declaration was effectively a "voluntary disclosure" and thus not entitled to scheme benefits. The discharge certificate was deemed non-conclusive, allowing tax authorities to proceed with recovery actions. The court rejected the petitioner's claims, emphasizing the importance of accurate tax reporting and adherence to scheme guidelines, ultimately dismissing the petition.
HC determined that the petitioner's declaration under SABKA VISHWAS (Legacy Dispute Resolution) Scheme, 2019 was invalid. The court found the declaration under "arrears category" contradictory, as the petitioner deliberately misled the system by filing incorrect tax details. The declaration was effectively a "voluntary disclosure" and thus not entitled to scheme benefits. The discharge certificate was deemed non-conclusive, allowing tax authorities to proceed with recovery actions. The court rejected the petitioner's claims, emphasizing the importance of accurate tax reporting and adherence to scheme guidelines, ultimately dismissing the petition.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
