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 held that the assessee failed to deposit 20% of the disputed demand (Rs. 69,05,933/-) as a pre-condition for staying the demand for AY 2016-17. The outstanding demand was consequently recovered from the refund due for AY 2014-15 through an appeal effect order. The court rejected the assessee's contention that the refund adjustment was contrary to the office memorandum, thereby upholding the tax authority's action of recovering the disputed amount through available refund mechanisms.
HC held that the assessee failed to deposit 20% of the disputed demand (Rs. 69,05,933/-) as a pre-condition for staying the demand for AY 2016-17. The outstanding demand was consequently recovered from the refund due for AY 2014-15 through an appeal effect order. The court rejected the assessee's contention that the refund adjustment was contrary to the office memorandum, thereby upholding the tax authority's action of recovering the disputed amount through available refund mechanisms.
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