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 adjudicated a tax settlement dispute concerning income disclosure and expense claims. The court held that the Income Tax Settlement Commission (ITSC) erroneously rejected applications under Section 245D(2C) without conducting a comprehensive factual investigation. The judicial determination mandated that the ITSC should have proceeded to the next procedural stage under Section 245D(4), thoroughly examining evidence supporting claimed expenses and determining appropriate tax liability. Consequently, the HC quashed the lower court's order, allowing the appellants' applications to be processed substantively, thereby ensuring a complete and fair adjudication of the tax settlement claims.
HC adjudicated a tax settlement dispute concerning income disclosure and expense claims. The court held that the Income Tax Settlement Commission (ITSC) erroneously rejected applications under Section 245D(2C) without conducting a comprehensive factual investigation. The judicial determination mandated that the ITSC should have proceeded to the next procedural stage under Section 245D(4), thoroughly examining evidence supporting claimed expenses and determining appropriate tax liability. Consequently, the HC quashed the lower court's order, allowing the appellants' applications to be processed substantively, thereby ensuring a complete and fair adjudication of the tax settlement claims.
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TaxTMI 
TaxTMI 
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