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...
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HC allowed the petition, finding SBI liable for cyber fraud losses. The court determined the petitioner was not negligent, as he did not share OTPs or payment credentials. The bank demonstrated significant service deficiency by failing to detect unusual transaction patterns, prevent unauthorized access, and take prompt action after fraud notification. The court held that the bank's security protocols were inadequate, breached by simple malware, and the Banking Ombudsman's order was legally unsustainable. The judgment emphasized the bank's duty to exercise reasonable care in protecting customer funds and responding to potential fraudulent transactions.
HC allowed the petition, finding SBI liable for cyber fraud losses. The court determined the petitioner was not negligent, as he did not share OTPs or payment credentials. The bank demonstrated significant service deficiency by failing to detect unusual transaction patterns, prevent unauthorized access, and take prompt action after fraud notification. The court held that the bank's security protocols were inadequate, breached by simple malware, and the Banking Ombudsman's order was legally unsustainable. The judgment emphasized the bank's duty to exercise reasonable care in protecting customer funds and responding to potential fraudulent transactions.
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