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 upheld the Tribunal's discretionary power in reducing pre-deposit penalty to 20% under Section 19(1)'s second proviso. The court affirmed that when legislative discretion is granted to an authority, its exercise depends solely on the authority's satisfaction and opinion. The Tribunal's decision was deemed procedurally correct, balancing potential undue hardship against penalty realization. The HC concluded that appellate forums cannot scrutinize the merits of the Tribunal's discretionary decision, thus declining to intervene in the original order.
HC upheld the Tribunal's discretionary power in reducing pre-deposit penalty to 20% under Section 19(1)'s second proviso. The court affirmed that when legislative discretion is granted to an authority, its exercise depends solely on the authority's satisfaction and opinion. The Tribunal's decision was deemed procedurally correct, balancing potential undue hardship against penalty realization. The HC concluded that appellate forums cannot scrutinize the merits of the Tribunal's discretionary decision, thus declining to intervene in the original order.
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