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 AT partly allowed the appeal by the appellant bank. The Tribunal held that penal liability under the relevant statutes accrues per transaction (each counterfeit-note disclosure) rather than per monthly reporting obligation, rendering the aggregate demand of Rs.5,40,000 (for 54 transactions) unlawful and noting the statutory minimum penalty of Rs.10,000 per transaction. Separately, the AT quashed the impugned Rs.200,000 penalty levied under Section 12A insofar as it related to the bank's alleged failure to furnish information, because the bank had furnished the requisite report by letter dated 26.12.2018 which the Director, FIU had ignored. The order below is modified accordingly.
The AT partly allowed the appeal by the appellant bank. The Tribunal held that penal liability under the relevant statutes accrues per transaction (each counterfeit-note disclosure) rather than per monthly reporting obligation, rendering the aggregate demand of Rs.5,40,000 (for 54 transactions) unlawful and noting the statutory minimum penalty of Rs.10,000 per transaction. Separately, the AT quashed the impugned Rs.200,000 penalty levied under Section 12A insofar as it related to the bank's alleged failure to furnish information, because the bank had furnished the requisite report by letter dated 26.12.2018 which the Director, FIU had ignored. The order below is modified accordingly.
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TaxTMI 
TaxTMI 
of 4918 
