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 dismissed prosecution proceedings against petitioner for TDS delay, finding no malicious intent. Despite procedural non-compliance, voluntary deposit of TDS with interest before show cause notice negated prosecution requirements. The court emphasized that mere technical breach does not automatically warrant penal action, particularly when the assessee has rectified the default proactively and no deliberate tax evasion was established. Interim protection continued, with no prosecution sanctioned against the petitioner-company.
HC dismissed prosecution proceedings against petitioner for TDS delay, finding no malicious intent. Despite procedural non-compliance, voluntary deposit of TDS with interest before show cause notice negated prosecution requirements. The court emphasized that mere technical breach does not automatically warrant penal action, particularly when the assessee has rectified the default proactively and no deliberate tax evasion was established. Interim protection continued, with no prosecution sanctioned against the petitioner-company.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
