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 appeal and affirmed the AT's impugned order dated 06.02.2019, holding the AA's confirmation of property retention legally unsustainable. The court observed that while leniency may apply to condonation of delay in re-filing appeals, appellants must still show sufficient cause; however, given prolonged pendency and prior consideration of delay, detailed scrutiny of a 143-day delay was unnecessary. Crucially, the AA failed to give reasoned findings as required by Sections 8(2) and 8(3) of the PMLA and could not rely on absence of the Respondent to avoid independent adjudication. The HC concluded that the AA's order was mechanical and void, and affirmed the AT's decision, dismissing the appeal.
The HC dismissed the appeal and affirmed the AT's impugned order dated 06.02.2019, holding the AA's confirmation of property retention legally unsustainable. The court observed that while leniency may apply to condonation of delay in re-filing appeals, appellants must still show sufficient cause; however, given prolonged pendency and prior consideration of delay, detailed scrutiny of a 143-day delay was unnecessary. Crucially, the AA failed to give reasoned findings as required by Sections 8(2) and 8(3) of the PMLA and could not rely on absence of the Respondent to avoid independent adjudication. The HC concluded that the AA's order was mechanical and void, and affirmed the AT's decision, dismissing the appeal.
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