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 set aside the order of the 1st respondent/Interim Board for Settlement-II rejecting the petitioner's third settlement application under section 245C. The Settlement Board had found non-disclosure of income relating to an alleged Rs. 18 Crores transaction from Smt. VK Sasikala, concluding the petitioner did not make full and true disclosure. However, the Adjudicating Authority had previously examined the transaction and concluded no such amount was received, a finding not considered by the Settlement Board. The HC held that the Settlement Board must base rejection on valid reasons and remanded the matter for fresh consideration in light of the Adjudicating Authority's findings. The impugned rejection order was quashed, and the 1st respondent was directed to reconsider the application afresh.
The HC set aside the order of the 1st respondent/Interim Board for Settlement-II rejecting the petitioner's third settlement application under section 245C. The Settlement Board had found non-disclosure of income relating to an alleged Rs. 18 Crores transaction from Smt. VK Sasikala, concluding the petitioner did not make full and true disclosure. However, the Adjudicating Authority had previously examined the transaction and concluded no such amount was received, a finding not considered by the Settlement Board. The HC held that the Settlement Board must base rejection on valid reasons and remanded the matter for fresh consideration in light of the Adjudicating Authority's findings. The impugned rejection order was quashed, and the 1st respondent was directed to reconsider the application afresh.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
