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 validity of document retention under section 133A during a survey, rejecting the petitioners' claim for return of impounded materials, as no physical books of account were seized. The court confirmed the petitioners' entitlement to certified copies of seized documents upon payment. Subsequent assessment orders were completed and upheld by the ITAT, rendering the writ petition infructuous. The court found the petitioners failed to substantiate share application money, relying on inadmissible loose papers, with findings corroborated by the Assessing Officer, CIT, and ITAT. The petitioners did not challenge compliance with orders to supply seized documents, negating claims of procedural irregularity. The HC distinguished survey from search operations, ruling that provisions under sections 153A-D apply only to searches, not surveys. Consequently, all contested questions were decided against the petitioners, affirming the legality of the survey and related assessment proceedings.
The HC upheld the validity of document retention under section 133A during a survey, rejecting the petitioners' claim for return of impounded materials, as no physical books of account were seized. The court confirmed the petitioners' entitlement to certified copies of seized documents upon payment. Subsequent assessment orders were completed and upheld by the ITAT, rendering the writ petition infructuous. The court found the petitioners failed to substantiate share application money, relying on inadmissible loose papers, with findings corroborated by the Assessing Officer, CIT, and ITAT. The petitioners did not challenge compliance with orders to supply seized documents, negating claims of procedural irregularity. The HC distinguished survey from search operations, ruling that provisions under sections 153A-D apply only to searches, not surveys. Consequently, all contested questions were decided against the petitioners, affirming the legality of the survey and related assessment proceedings.
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