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 held that assessment proceedings initiated against an assessee undergoing Corporate Insolvency Resolution Process were invalid as they violated the Moratorium under Section 14 of the IBC, 2016. The Moratorium prohibits initiation or continuation of such proceedings during its operation. Consequently, the assessment proceedings initiated during this period were quashed. However, the court clarified that upon cessation of the Moratorium, the Revenue may lawfully revive the assessment proceedings if entitled to do so under applicable law.
The HC held that assessment proceedings initiated against an assessee undergoing Corporate Insolvency Resolution Process were invalid as they violated the Moratorium under Section 14 of the IBC, 2016. The Moratorium prohibits initiation or continuation of such proceedings during its operation. Consequently, the assessment proceedings initiated during this period were quashed. However, the court clarified that upon cessation of the Moratorium, the Revenue may lawfully revive the assessment proceedings if entitled to do so under applicable law.
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