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 found the SCN uploaded in 'Additional Notices Tab' violated principles of natural justice, rendering the impugned order dated 5th August, 2024 invalid. The court remanded the matter back to the Adjudicating Authority, granting the Petitioner time until 10th July 2025 to file a reply to the SCN. Upon reply submission, the Authority must issue a personal hearing notice. The impugned order was set aside, and the petition was allowed through remand, ensuring procedural fairness and opportunity to be heard.
HC found the SCN uploaded in 'Additional Notices Tab' violated principles of natural justice, rendering the impugned order dated 5th August, 2024 invalid. The court remanded the matter back to the Adjudicating Authority, granting the Petitioner time until 10th July 2025 to file a reply to the SCN. Upon reply submission, the Authority must issue a personal hearing notice. The impugned order was set aside, and the petition was allowed through remand, ensuring procedural fairness and opportunity to be heard.
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