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 dismissed the petitioner's writ insofar as it sought premature interference with the respondent's tax notice, holding that the petitioner failed to file the requisite reply to the impugned notice dated 18.03.2025 and thus cannot seek relief before the Court without exhausting the statutory process. The Court found that the petitioner bears the evidentiary burden to substantiate entitlement to the lower TDS rate where the seller's PAN was not linked to Aadhaar at the relevant time. The HC directed the Petitioner to file a substantive reply with supporting documents within two weeks of receipt of this order, and directed the Respondent to consider that reply and pass a decision expeditiously.
The HC dismissed the petitioner's writ insofar as it sought premature interference with the respondent's tax notice, holding that the petitioner failed to file the requisite reply to the impugned notice dated 18.03.2025 and thus cannot seek relief before the Court without exhausting the statutory process. The Court found that the petitioner bears the evidentiary burden to substantiate entitlement to the lower TDS rate where the seller's PAN was not linked to Aadhaar at the relevant time. The HC directed the Petitioner to file a substantive reply with supporting documents within two weeks of receipt of this order, and directed the Respondent to consider that reply and pass a decision expeditiously.
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