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 allowed the petition, holding that the two SCNs relate to the same matter and the discharge certificate issued under the SVLDR Scheme conclusively terminates proceedings arising from those SCNs. The Court held petitioners are not ineligible under Section 125(1)(a) and their declarations under the Scheme stand valid. Redemption fine arising from seizure and release is a consequence of non-payment of excise duty and falls within the ambit of "duty"/"penalty" under the SVLDR Scheme, so it is covered by the Scheme's settlement mechanism; applicable percentages under Section 129 apply and any appellate pre-deposit is deductible under Section 124(2) though not refundable.
The HC allowed the petition, holding that the two SCNs relate to the same matter and the discharge certificate issued under the SVLDR Scheme conclusively terminates proceedings arising from those SCNs. The Court held petitioners are not ineligible under Section 125(1)(a) and their declarations under the Scheme stand valid. Redemption fine arising from seizure and release is a consequence of non-payment of excise duty and falls within the ambit of "duty"/"penalty" under the SVLDR Scheme, so it is covered by the Scheme's settlement mechanism; applicable percentages under Section 129 apply and any appellate pre-deposit is deductible under Section 124(2) though not refundable.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
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