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...
The HC dismissed the revenue's attempt to reopen concluded proceedings arising from delayed employee contributions to statutory funds, holding that a subsequent change in law or later SC determinations do not constitute a proper ground for review of final adjudications. The Tribunal's order was assessed on the law prevailing when it was rendered, and a later judicial development cannot exume or revive a closed determination; at best it governs future adjudications. Given settled authority that change of law alone does not warrant re-opening concluded matters, the HC declined to remit the matter for fresh consideration and directed the parties to abide by the operative law at the time of the original decision.
The HC dismissed the revenue's attempt to reopen concluded proceedings arising from delayed employee contributions to statutory funds, holding that a subsequent change in law or later SC determinations do not constitute a proper ground for review of final adjudications. The Tribunal's order was assessed on the law prevailing when it was rendered, and a later judicial development cannot exume or revive a closed determination; at best it governs future adjudications. Given settled authority that change of law alone does not warrant re-opening concluded matters, the HC declined to remit the matter for fresh consideration and directed the parties to abide by the operative law at the time of the original decision.
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