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...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
HC held that the State tax authority possesses statutory power under the non-obstante provision of Section 44 to recover tax dues by attaching amounts owed to a dealer, which includes subsidy payments due to an industry under central industrial policies once those claims are processed, approved by the competent State Committees, sanctioned by the DIPP and released via the designated disbursing agency. The court construed "any person from whom any amount is due or may become due" and "any person who holds or may subsequently hold" to encompass persons holding sanctioned subsidy proceeds, enabling recovery forthwith upon such amounts becoming due or held. The writ petitions are disposed of.
HC held that the State tax authority possesses statutory power under the non-obstante provision of Section 44 to recover tax dues by attaching amounts owed to a dealer, which includes subsidy payments due to an industry under central industrial policies once those claims are processed, approved by the competent State Committees, sanctioned by the DIPP and released via the designated disbursing agency. The court construed "any person from whom any amount is due or may become due" and "any person who holds or may subsequently hold" to encompass persons holding sanctioned subsidy proceeds, enabling recovery forthwith upon such amounts becoming due or held. The writ petitions are disposed of.
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