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 remanded the matter to HC, directing expedited review of an ex-parte assessment reopening order. The court mandated HC to adjudicate the pending review petition within four weeks, preserving the petitioner's right to seek alternative legal remedies if the outcome is unfavorable. The decision emphasizes procedural fairness by allowing the petitioner an opportunity to challenge the original ex-parte order regarding tax assessment exemption under Sections 11 and 12, while maintaining judicial economy through time-bound resolution.
SC remanded the matter to HC, directing expedited review of an ex-parte assessment reopening order. The court mandated HC to adjudicate the pending review petition within four weeks, preserving the petitioner's right to seek alternative legal remedies if the outcome is unfavorable. The decision emphasizes procedural fairness by allowing the petitioner an opportunity to challenge the original ex-parte order regarding tax assessment exemption under Sections 11 and 12, while maintaining judicial economy through time-bound resolution.
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