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 upheld the refusal to recognize the petitioner's SPEC industrial division as a "Non Resident Dealer" under the specified exemption notification. The court distinguished this case from precedents involving adjacent units with inter-unit transfers or expansions, noting that the SPEC division manufactures distinct products from the petitioner's original unit, thereby qualifying as a separate unit under the notification. Consequently, the petitioner was liable for tax assessments for AY 2005-06 through 2009-10. The petitioner's challenge to the revision orders issued by the MP Commercial Board was dismissed, as the respondents correctly assessed tax based on the denial of Non Resident Dealer status for the SPEC division. The HC found no merit in the writ petitions and accordingly dismissed them.
The HC upheld the refusal to recognize the petitioner's SPEC industrial division as a "Non Resident Dealer" under the specified exemption notification. The court distinguished this case from precedents involving adjacent units with inter-unit transfers or expansions, noting that the SPEC division manufactures distinct products from the petitioner's original unit, thereby qualifying as a separate unit under the notification. Consequently, the petitioner was liable for tax assessments for AY 2005-06 through 2009-10. The petitioner's challenge to the revision orders issued by the MP Commercial Board was dismissed, as the respondents correctly assessed tax based on the denial of Non Resident Dealer status for the SPEC division. The HC found no merit in the writ petitions and accordingly dismissed them.
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TaxTMI 
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