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 upheld that the adjudicating authority shall follow binding appellate precedents of the jurisdictional appellate forum; orders of an Appellate Collector and of the Tribunal bind subordinate Assistant Collectors within their respective jurisdictions. Applying the doctrine of judicial discipline, the HC directed that subordinate authorities must implement higher appellate orders notwithstanding departmental disagreement, unless the order's operation has been lawfully stayed by a competent court. Noncompliance would constitute undue harassment and administrative chaos. Having regard to these conclusions and the parties' submissions, the court issued a notice returnable on 2.9.2025 and permitted direct service by e-mail.
The HC upheld that the adjudicating authority shall follow binding appellate precedents of the jurisdictional appellate forum; orders of an Appellate Collector and of the Tribunal bind subordinate Assistant Collectors within their respective jurisdictions. Applying the doctrine of judicial discipline, the HC directed that subordinate authorities must implement higher appellate orders notwithstanding departmental disagreement, unless the order's operation has been lawfully stayed by a competent court. Noncompliance would constitute undue harassment and administrative chaos. Having regard to these conclusions and the parties' submissions, the court issued a notice returnable on 2.9.2025 and permitted direct service by e-mail.
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