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...
The HC dismissed the petition, emphasizing the availability of an alternative and efficacious statutory remedy which the petitioner failed to utilize. The court held that the petitioner's attempt to circumvent the mandatory pre-deposit requirement for instituting an appeal was unjustified. The HC reaffirmed the principle that extraordinary jurisdiction under Article 226 cannot be exercised to bypass prescribed statutory procedures unless stringent conditions, as established by precedent, are met. The decision aligns with the SC's recent stance that statutory remedies should not be circumvented through constitutional petitions, thereby upholding the integrity of the statutory appeal process.
The HC dismissed the petition, emphasizing the availability of an alternative and efficacious statutory remedy which the petitioner failed to utilize. The court held that the petitioner's attempt to circumvent the mandatory pre-deposit requirement for instituting an appeal was unjustified. The HC reaffirmed the principle that extraordinary jurisdiction under Article 226 cannot be exercised to bypass prescribed statutory procedures unless stringent conditions, as established by precedent, are met. The decision aligns with the SC's recent stance that statutory remedies should not be circumvented through constitutional petitions, thereby upholding the integrity of the statutory appeal process.
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