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...
HC determined priority of claims between secured creditor bank and Commercial Taxes Department. The court held that Section 26E of SARFAESI Act and Section 34 of RDB Act prevail over Section 24 of TNGST Act. The bank's equitable mortgage created in 1991 takes precedence over sales tax arrears. The court quashed the impugned notices, finding the bank's security interest legitimate and prioritized over government revenue claims, thereby allowing the writ petitions in the interest of public policy and legal consistency.
HC determined priority of claims between secured creditor bank and Commercial Taxes Department. The court held that Section 26E of SARFAESI Act and Section 34 of RDB Act prevail over Section 24 of TNGST Act. The bank's equitable mortgage created in 1991 takes precedence over sales tax arrears. The court quashed the impugned notices, finding the bank's security interest legitimate and prioritized over government revenue claims, thereby allowing the writ petitions in the interest of public policy and legal consistency.
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