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 analyzed TDS provisions regarding "payable" vs. "paid" interpretations. The court found the lower tribunal's order erroneous based on a previously overruled HC judgment. Applying SC precedent in Palam Gas Service and Directorate of Revenue Intelligence cases, the court determined the term "payable" has a specific legal meaning distinct from actual payment. Consequently, the HC set aside the ITAT Ranchi order and remitted the matter for fresh adjudication, directing the tribunal to reconsider the issue in light of the SC's interpretation of Section 40(a)(ia) and subsequent legal principles governing tax deduction at source.
HC analyzed TDS provisions regarding "payable" vs. "paid" interpretations. The court found the lower tribunal's order erroneous based on a previously overruled HC judgment. Applying SC precedent in Palam Gas Service and Directorate of Revenue Intelligence cases, the court determined the term "payable" has a specific legal meaning distinct from actual payment. Consequently, the HC set aside the ITAT Ranchi order and remitted the matter for fresh adjudication, directing the tribunal to reconsider the issue in light of the SC's interpretation of Section 40(a)(ia) and subsequent legal principles governing tax deduction at source.
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