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 found the Trial Court's proceedings in MISC DJ/3623/2024 without jurisdiction, constituting a patent error on the record. Invoking Article 227 of the Constitution, the HC set aside the Trial Court's order dated 17.01.2025 and all subsequent proceedings. The Court emphasized that a court cannot suo moto confer jurisdiction where it statutorily lacks authority. The petition was allowed, effectively nullifying the Trial Court's actions and ensuring adherence to principles of equity, justice, and legal propriety.
HC found the Trial Court's proceedings in MISC DJ/3623/2024 without jurisdiction, constituting a patent error on the record. Invoking Article 227 of the Constitution, the HC set aside the Trial Court's order dated 17.01.2025 and all subsequent proceedings. The Court emphasized that a court cannot suo moto confer jurisdiction where it statutorily lacks authority. The petition was allowed, effectively nullifying the Trial Court's actions and ensuring adherence to principles of equity, justice, and legal propriety.
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