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 found violation of the principles of natural justice for non-consideration of the reply to notice DRC 01A and quashed the impugned assessment order insofar as it reflected the retrospective rate change from 12% to 18% under the notification. The writ petition was disposed of by setting aside the assessment on terms: the petitioner must deposit 25% of the disputed tax from the Electronic Credit Ledger within 30 days of receipt of the order. Subject to this deposit and compliance with the terms, the impugned order stands quashed; no different remedial course was warranted on the facts and circumstances before the HC.
The HC found violation of the principles of natural justice for non-consideration of the reply to notice DRC 01A and quashed the impugned assessment order insofar as it reflected the retrospective rate change from 12% to 18% under the notification. The writ petition was disposed of by setting aside the assessment on terms: the petitioner must deposit 25% of the disputed tax from the Electronic Credit Ledger within 30 days of receipt of the order. Subject to this deposit and compliance with the terms, the impugned order stands quashed; no different remedial course was warranted on the facts and circumstances before the HC.
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