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 petitioner's challenge to warrant of authorization regarding seizure of gold jewellery worth Rs. 1,07,70,042. Following seizure, Income Tax Authority served notices under Sections 142(1) and 143(2) of Income Tax Act, passed final assessment order on 24.12.2019 creating demand of Rs. 1.08 crores. Petitioner's appeal against assessment order was dismissed. Court held petitioner cannot challenge warrant of authorization after finalization of assessment proceedings and dismissal of appeal. Income Tax Authority properly rejected release application due to pending tax demand. Court ruled petition misconceived as proper remedy lies before Income Tax Appellate Tribunal under Section 132-B of Income Tax Act. Petition dismissed.
HC dismissed petitioner's challenge to warrant of authorization regarding seizure of gold jewellery worth Rs. 1,07,70,042. Following seizure, Income Tax Authority served notices under Sections 142(1) and 143(2) of Income Tax Act, passed final assessment order on 24.12.2019 creating demand of Rs. 1.08 crores. Petitioner's appeal against assessment order was dismissed. Court held petitioner cannot challenge warrant of authorization after finalization of assessment proceedings and dismissal of appeal. Income Tax Authority properly rejected release application due to pending tax demand. Court ruled petition misconceived as proper remedy lies before Income Tax Appellate Tribunal under Section 132-B of Income Tax Act. Petition dismissed.
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