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 allowed the writ petition and held that, pursuant to the Principal Bench ruling, the tax authorities are entitled to exclude the period 15.03.2020 to 28.02.2022 when computing limitation under the relevant provisions, thereby entitling the petitioner to relief. Consequently, the impugned assessment order dated 16.08.2024 issued by the first respondent for the assessment year 2019-2020 is quashed. The matter is remitted to the first respondent for fresh adjudication on merits and in accordance with law, taking into account the exclusion of the specified period; no order as to costs.
The HC allowed the writ petition and held that, pursuant to the Principal Bench ruling, the tax authorities are entitled to exclude the period 15.03.2020 to 28.02.2022 when computing limitation under the relevant provisions, thereby entitling the petitioner to relief. Consequently, the impugned assessment order dated 16.08.2024 issued by the first respondent for the assessment year 2019-2020 is quashed. The matter is remitted to the first respondent for fresh adjudication on merits and in accordance with law, taking into account the exclusion of the specified period; no order as to costs.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
