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...
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HC allows petitioner's challenge to DTVSV Scheme declaration rejection. The court found the non-disclosure of pending writ petition was immaterial and directed the Designated Authority to process the declaration. The authority must determine the payable amount in accordance with DTVSV Scheme provisions, using the original declaration date of 23.12.2024. The court emphasized that the petitioner's waiver of rights and commitment to withdraw the writ petition upon certificate issuance were valid. The ruling effectively mandates the administrative authority to proceed with the declaration processing without technical objections.
HC allows petitioner's challenge to DTVSV Scheme declaration rejection. The court found the non-disclosure of pending writ petition was immaterial and directed the Designated Authority to process the declaration. The authority must determine the payable amount in accordance with DTVSV Scheme provisions, using the original declaration date of 23.12.2024. The court emphasized that the petitioner's waiver of rights and commitment to withdraw the writ petition upon certificate issuance were valid. The ruling effectively mandates the administrative authority to proceed with the declaration processing without technical objections.
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