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 under Section 9(a)(i) of the Direct Tax Vivad Se Vishwas Act, 2020, declarants are precluded from settling disputes where tax arrears relate to assessments under Sections 143(3), 144, 153A, or 153C following a search under Section 132, and where disputed tax exceeds Rs. 5,00,00,000/-. The petitioners' assessments arising from search proceedings on 24.09.2015 with assessment orders dated 28.04.2017 and 27.04.2017 respectively exceeded the prescribed threshold. Consequently, the petitioners were ineligible for amnesty scheme benefits, irrespective of having paid taxes, consistent with CBDT circulars interpreting the statutory provisions.
HC held that under Section 9(a)(i) of the Direct Tax Vivad Se Vishwas Act, 2020, declarants are precluded from settling disputes where tax arrears relate to assessments under Sections 143(3), 144, 153A, or 153C following a search under Section 132, and where disputed tax exceeds Rs. 5,00,00,000/-. The petitioners' assessments arising from search proceedings on 24.09.2015 with assessment orders dated 28.04.2017 and 27.04.2017 respectively exceeded the prescribed threshold. Consequently, the petitioners were ineligible for amnesty scheme benefits, irrespective of having paid taxes, consistent with CBDT circulars interpreting the statutory provisions.
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