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 held that principles of natural justice were violated when petitioner was denied personal hearing despite sufficient time between response filing and order issuance. The authority failed to provide opportunity under Section 75(4), which mandates hearing before adverse order. Given potential substantive arguments in petitioner's response, the procedural defect was material. The impugned order was consequently set aside, with petition allowed, emphasizing the critical importance of procedural fairness in administrative proceedings.
HC held that principles of natural justice were violated when petitioner was denied personal hearing despite sufficient time between response filing and order issuance. The authority failed to provide opportunity under Section 75(4), which mandates hearing before adverse order. Given potential substantive arguments in petitioner's response, the procedural defect was material. The impugned order was consequently set aside, with petition allowed, emphasizing the critical importance of procedural fairness in administrative proceedings.
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TaxTMI 
TaxTMI 
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