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 rejected the Petitioner's application for forensic document analysis under Section 528 of Bharatiya Nagarik Suraksha Sanhita, 2023. The Court found the request untimely and procedurally defective, noting the Petitioners' failure to provide substantive explanations for the delayed forensic examination request. Despite opportunities for cross-examination and defense presentation, the Petitioners did not lead credible evidence to support their claim. The Court emphasized that the Complaint already highlighted signature discrepancies, and the application was filed at the final arguments stage without compelling justification. Consequently, the petition was dismissed, with the Court underscoring the inadmissibility of conjecture and presumption in legal proceedings.
HC rejected the Petitioner's application for forensic document analysis under Section 528 of Bharatiya Nagarik Suraksha Sanhita, 2023. The Court found the request untimely and procedurally defective, noting the Petitioners' failure to provide substantive explanations for the delayed forensic examination request. Despite opportunities for cross-examination and defense presentation, the Petitioners did not lead credible evidence to support their claim. The Court emphasized that the Complaint already highlighted signature discrepancies, and the application was filed at the final arguments stage without compelling justification. Consequently, the petition was dismissed, with the Court underscoring the inadmissibility of conjecture and presumption in legal proceedings.
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